How to read the money
Income and expense are whole-filing amounts associated with this lobbyist, not personal compensation or an allocated share.
No topic inference: each bill number appears in source LDA issue text assigned to this lobbyist.
Investing in Our Communities Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for regulations implementing 26 USC 7701(51)(D)(i)(I)(dd) regarding the prohibited foreign entity debt test (15 percent) to exempt publicly offered debt or stipulate that the underwriter of publicly offered debt is the issuee for purposes of the text. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts and acquisition of existing output facilities to serve large load customers. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817). Discussed potential changes to 26 USC 6417, elective payment energy tax credits, including unspecified changes to the domestic content requirements for elective payment imposed under sections 48E (investment tax credit) and 45Y (production tax credit). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed the importance of municipal bonds, which are used by public power utilities to build energy infrastructure. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million. Discussed support for S. 5453, the Grid Resiliency Tax Credit Act, to amend the Internal Revenue Code to establish a tax credit for the installation of regionally significant electric power transmission lines. Discussed the potential effect of energy and natural gas prepayment transactions on tax-exempt financing.
Specific issues are shown only where the LDA source assigned them to this lobbyist. Targets apply to the associated filing.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2026 · third_quarter · Q3
Discussed concerns with proposed changes to the operation of the Federal Emergency Management Agency (FEMA) as proposed by the FEMA Reform Council in its Final Report (changes to disaster designation methodology, public assistance calculations, and converting public assistance into block grants). Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Discussed draft legislation to improve resilience, including support for improving FEMA resilience and hazard mitigation programs to explicitly support projects involving energy storage, microgrids, distributed energy resources, community resilience bubs, and energy resilience for critical facilities.
Source: Senate LDA
Investing in Our Communities Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support for regulations implementing 26 USC 7701(51)(D)(i)(I)(dd) regarding the prohibited foreign entity debt test (15 percent) to exempt publicly offered debt or stipulate that the underwriter of publicly offered debt is the issuee for purposes of the text. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts and acquisition of existing output facilities to serve large load customers. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817). Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for simplifying the qualification for elective payment under 26 USC 6417 (no legislation). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed the importance of municipal bonds, which are used by public power utilities to build energy infrastructure. Discussed support for S. 1481, the Lifting Our Communities through Advanced Liquidity for Infrastructure Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million. Discussed opposition to proposed changes to tax-exempt financing to encourage the privatization of public infrastructure through asset recycling (no legislation). Discussed the potential effect of energy and natural gas prepayment transactions on tax-exempt financing.
Investing in Our Communities Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817) and the need for clarity from the Treasury Department on the implementation of section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million.
POWER Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act of 2025, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities.
Maintaining and Enhancing Hydroelectricity and River Restoration Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support for regulations implementing 26 USC 7701(51)(D)(i)(I)(dd) regarding the prohibited foreign entity debt test (15 percent) to exempt publicly offered debt or stipulate that the underwriter of publicly offered debt is the issuee for purposes of the text. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts and acquisition of existing output facilities to serve large load customers. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817). Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for simplifying the qualification for elective payment under 26 USC 6417 (no legislation). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed the importance of municipal bonds, which are used by public power utilities to build energy infrastructure. Discussed support for S. 1481, the Lifting Our Communities through Advanced Liquidity for Infrastructure Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million. Discussed opposition to proposed changes to tax-exempt financing to encourage the privatization of public infrastructure through asset recycling (no legislation). Discussed the potential effect of energy and natural gas prepayment transactions on tax-exempt financing.
Maintaining and Enhancing Hydroelectricity and River Restoration Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817) and the need for clarity from the Treasury Department on the implementation of section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million.
Religious Workforce Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act of 2025, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities.
FEMA Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed concerns with proposed changes to the operation of the Federal Emergency Management Agency (FEMA) as proposed by the FEMA Reform Council in its Final Report (changes to disaster designation methodology, public assistance calculations, and converting public assistance into block grants). Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Discussed draft legislation to improve resilience, including support for improving FEMA resilience and hazard mitigation programs to explicitly support projects involving energy storage, microgrids, distributed energy resources, community resilience bubs, and energy resilience for critical facilities.
FEMA Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act of 2025, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities.
FEMA Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed concerns with proposed changes to the operation of the Federal Emergency Management Agency (FEMA) as proposed by the FEMA Reform Council in its Final Report (changes to disaster designation methodology, public assistance calculations, and converting public assistance into block grants). Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure.
Homeland Security and Further Additional Continuing Appropriations Act, 2026.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for increased funding for the Low Income Home Energy Assistance Program and efforts to ensure the timely disbursement of funds to states (LIHEAP)(no legislation). Discussed support for section 4 of H.R. 7147, the Homeland Security and Further Additional Continuing Appropriations Act, 2026, which incorporates by reference the Joint Explanatory Statement that prescribes Federal Emergency Management Agency actions regarding disaster designations, BRIC grants, public assistance payments, and staffing.
Rural and Municipal Utility Cybersecurity Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
AI Fraud Accountability Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Hydropower Licensing Affordability Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support for regulations implementing 26 USC 7701(51)(D)(i)(I)(dd) regarding the prohibited foreign entity debt test (15 percent) to exempt publicly offered debt or stipulate that the underwriter of publicly offered debt is the issuee for purposes of the text. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts and acquisition of existing output facilities to serve large load customers. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817). Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for simplifying the qualification for elective payment under 26 USC 6417 (no legislation). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed the importance of municipal bonds, which are used by public power utilities to build energy infrastructure. Discussed support for S. 1481, the Lifting Our Communities through Advanced Liquidity for Infrastructure Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million. Discussed opposition to proposed changes to tax-exempt financing to encourage the privatization of public infrastructure through asset recycling (no legislation). Discussed the potential effect of energy and natural gas prepayment transactions on tax-exempt financing.
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817) and the need for clarity from the Treasury Department on the implementation of section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million.
LOCAL Infrastructure Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support for regulations implementing 26 USC 7701(51)(D)(i)(I)(dd) regarding the prohibited foreign entity debt test (15 percent) to exempt publicly offered debt or stipulate that the underwriter of publicly offered debt is the issuee for purposes of the text. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts and acquisition of existing output facilities to serve large load customers. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817). Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for simplifying the qualification for elective payment under 26 USC 6417 (no legislation). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed the importance of municipal bonds, which are used by public power utilities to build energy infrastructure. Discussed support for S. 1481, the Lifting Our Communities through Advanced Liquidity for Infrastructure Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million. Discussed opposition to proposed changes to tax-exempt financing to encourage the privatization of public infrastructure through asset recycling (no legislation). Discussed the potential effect of energy and natural gas prepayment transactions on tax-exempt financing.
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Grid Resiliency Tax Credit Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for regulations implementing 26 USC 7701(51)(D)(i)(I)(dd) regarding the prohibited foreign entity debt test (15 percent) to exempt publicly offered debt or stipulate that the underwriter of publicly offered debt is the issuee for purposes of the text. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts and acquisition of existing output facilities to serve large load customers. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817). Discussed potential changes to 26 USC 6417, elective payment energy tax credits, including unspecified changes to the domestic content requirements for elective payment imposed under sections 48E (investment tax credit) and 45Y (production tax credit). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed the importance of municipal bonds, which are used by public power utilities to build energy infrastructure. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million. Discussed support for S. 5453, the Grid Resiliency Tax Credit Act, to amend the Internal Revenue Code to establish a tax credit for the installation of regionally significant electric power transmission lines. Discussed the potential effect of energy and natural gas prepayment transactions on tax-exempt financing.
To designate the facility of the United States Postal Service located at 9355 113th Street in Seminole, Florida, as the "Army SSG Ryan Christian Knauss Memorial Post Office Building".
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Energy Permitting Reform Act of 2024
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from the Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025). Discussed opposition to Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025) section 70513(b) (restrictions relating to prohibited foreign entities) provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to H.R. 1, section 70513(b) (restrictions relating to prohibited foreign entities) as passed by the House, provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to section 70512(f), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, and section 70513(a), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, in Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed Elective Pay Blueprint APPA developed for APPA members to guide them on energy tax credits. Discussed support for S. 1481, the LOCAL Infrastructure Act, to reinstate advance refunding bonds. Discussed support for S. 5212, the Enhanced Energy Recovery Act, provisions ensuring tax credits for expanding carbon capture are available via elective payment.
Establishing the congressional budget for the United States Government for fiscal year 2025 and setting forth the appropriate budgetary levels for fiscal years 2026 through 2034.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for possible legislation to amend 26 USC 6417, elective payment of energy tax credits. Discussed opposition to possible guidance superseding IRS Notice 2013-29, defining beginning of construction for purposes of designating a qualifying facility for certain clean energy projects. Discussed support of possible guidance relating to 26 USC 45U, existing nuclear tax credit, and 26 USC 7701(51)(a), prohibited foreign entity debt test. Discussed the need for the Treasury Department to issue 45U tax guidance for existing nuclear tax credits (no legislation). Discussed possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for possible regulations to implement section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for possible regulations to 26 USC 6417, elective payment of energy tax credits. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for possible legislation to waiver 2 USC 20A, Statutory Pay-as-You-Go, in relation to the budget effects of P.L. 119-21, the One Big, Beautiful Bill Act of 2025.
An act to provide for reconciliation pursuant to title II of H. Con. Res. 14.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from the Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025). Discussed opposition to Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025) section 70513(b) (restrictions relating to prohibited foreign entities) provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to H.R. 1, section 70513(b) (restrictions relating to prohibited foreign entities) as passed by the House, provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to section 70512(f), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, and section 70513(a), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, in Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed Elective Pay Blueprint APPA developed for APPA members to guide them on energy tax credits. Discussed support for S. 1481, the LOCAL Infrastructure Act, to reinstate advance refunding bonds. Discussed support for S. 5212, the Enhanced Energy Recovery Act, provisions ensuring tax credits for expanding carbon capture are available via elective payment.
GRID Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
GRID Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
Investing in Our Communities Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies and expressed concerns with any legislative efforts to eliminate them. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed tax credits for hydropower (no legislation). Discussed support for H.R. 1255, the Investing in Our Communities Act, to reinstate the ability to issue tax-exempt advanced refunding bonds.
New Source Review Permitting Improvement Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed the proposed rulemaking to revise the definition of Waters of the United States and implementation changes. Also discussed ways to strengthen the proposal (Docket ID No.: EPA-OW-2025-0322; FRL 11132.1-01-OW).
POWER Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities.
POWER Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for S. 1429/H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities. Discussed opposition to the repeal of the Stafford Act (no legislation). Provided feedback to draft legislation, the Fixing Emergency Management for Americans (FEMA) Act, including section 101, to replace existing section 406 cost-based grants with new Stafford Act section 409 estimate-based grants.
ESA Amendments Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under NEPA (all provisions). Discussed support of reforms to the Endangered Species Act that would change the definition of habitat (no legislation). Discussed how the Endangered Species Act impacts energy infrastructure projects (no legislation). Discussed H.R. 1897, the Endangered Species Act Amendments of 2025 (all provisions). Discussed the importance of the Endangered Species Act for public power utilities and some of the challenges the statute creates (Docket No. FWS-HQ-ES-2025-0039, FWS-HQ-ES-2025-0048, FWS-HQ-ES-2025-0029, and FWS-HQ-ES-2025-0044).
Maintaining and Enhancing Hydroelectricity and River Restoration Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for possible legislation to amend 26 USC 6417, elective payment of energy tax credits. Discussed opposition to possible guidance superseding IRS Notice 2013-29, defining beginning of construction for purposes of designating a qualifying facility for certain clean energy projects. Discussed support of possible guidance relating to 26 USC 45U, existing nuclear tax credit, and 26 USC 7701(51)(a), prohibited foreign entity debt test. Discussed the need for the Treasury Department to issue 45U tax guidance for existing nuclear tax credits (no legislation). Discussed possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for possible regulations to implement section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for possible regulations to 26 USC 6417, elective payment of energy tax credits. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for possible legislation to waiver 2 USC 20A, Statutory Pay-as-You-Go, in relation to the budget effects of P.L. 119-21, the One Big, Beautiful Bill Act of 2025.
Maintaining and Enhancing Hydroelectricity and River Restoration Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Southwestern Power Administration Fund Establishment Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Religious Workforce Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for S. 1429/H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities. Discussed opposition to the repeal of the Stafford Act (no legislation). Provided feedback to draft legislation, the Fixing Emergency Management for Americans (FEMA) Act, including section 101, to replace existing section 406 cost-based grants with new Stafford Act section 409 estimate-based grants.
Religious Workforce Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 2836, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed the need for FEMA reform (no legislation). Provided feedback on draft legislation, the Fixing Emergency Management for Americans (FEMA) Act, including section 101, to replace existing section 406 cost-based grants with new Stafford Act section 409 estimate-based grants and section 301, expanding preapproved hazard mitigation lists to include public power. Also discussed section 117 on expedited funding for emergency work, section 118 to clarify the definition of local in constancy in procurement practices, and section 122 on loan interest payment relief. Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Provided feedback on draft legislation to reform the Stafford Act to allow for better grid technology when rebuilding downed power lines after a disaster. Discussed the termination of the Building Resilient Infrastructure and Communities program at FEMA, which provides funding to support eligible entities undertaking pre-disaster and hazard mitigation projects or capability and capacity building activities to reduce their risks from disasters and natural hazards.
Religious Workforce Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities.
FEMA Loan Interest Payment Relief Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 2836, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed the need for FEMA reform (no legislation). Provided feedback on draft legislation, the Fixing Emergency Management for Americans (FEMA) Act, including section 101, to replace existing section 406 cost-based grants with new Stafford Act section 409 estimate-based grants and section 301, expanding preapproved hazard mitigation lists to include public power. Also discussed section 117 on expedited funding for emergency work, section 118 to clarify the definition of local in constancy in procurement practices, and section 122 on loan interest payment relief. Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Provided feedback on draft legislation to reform the Stafford Act to allow for better grid technology when rebuilding downed power lines after a disaster. Discussed the termination of the Building Resilient Infrastructure and Communities program at FEMA, which provides funding to support eligible entities undertaking pre-disaster and hazard mitigation projects or capability and capacity building activities to reduce their risks from disasters and natural hazards.
Help Hoover Dam Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Reliable Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Reliable Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed potential legislation regarding the Energy Threat Analysis Center and obstacles to increased public power participation. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the urgent need for a replacement for the public disclosure exemptions that were provided under the Critical Infrastructure Partnership Advisory Council to facilitate information sharing at Electricity Subsector Coordinating Council meetings (no legislation). Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for S. 1337, the Cybersecurity Information Sharing Extension Act (all provisions). Discussed support for H.R. 5079, the Widespread Information Management for the Welfare of Infrastructure and Government Act (all provisions). Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed support of H.R. 3657, the Hydropower Licensing Transparency Act, to direct the Federal Energy Regulatory Commission (FERC) to report annually to Congress on the status of the relicensing process for each application for a renewed hydropower dam license. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, from the 118th Congress, which would have expanded the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would have exempted Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed grid-enhancing technologies (GETS) and interconnection queue reform. Also discussed the need to ensure savings related to GETS benefits public power utilities and their customers (no bill). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Provided feedback on a draft bill to create a new must consider provision under section 111(d) of the Public Utility Regulatory Policy Act that would seek to create interconnection procedures to support microgrids. Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions, including issues in Docket AD25-7. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the North American Electric Reliability Corporations (NERC) electric reliability standards development procedures and the impact of FERC Order No. 907 (directing modifications to NERCs critical infrastructure protection standards) on the prioritization of NERCs standards development work. Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Reliable Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Energy Choice Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Baseload Reliability Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
PERMIT Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed the proposed rulemaking to revise the definition of Waters of the United States and implementation changes. Also discussed ways to strengthen the proposal (Docket ID No.: EPA-OW-2025-0322; FRL 11132.1-01-OW).
Vietnam Veteran Commemoration Fund Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Vietnam Veteran Commemoration Fund Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Vietnam Veteran Commemoration Fund Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
FEMA Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 2836, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed the need for FEMA reform (no legislation). Provided feedback on draft legislation, the Fixing Emergency Management for Americans (FEMA) Act, including section 101, to replace existing section 406 cost-based grants with new Stafford Act section 409 estimate-based grants and section 301, expanding preapproved hazard mitigation lists to include public power. Also discussed section 117 on expedited funding for emergency work, section 118 to clarify the definition of local in constancy in procurement practices, and section 122 on loan interest payment relief. Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Provided feedback on draft legislation to reform the Stafford Act to allow for better grid technology when rebuilding downed power lines after a disaster. Discussed the termination of the Building Resilient Infrastructure and Communities program at FEMA, which provides funding to support eligible entities undertaking pre-disaster and hazard mitigation projects or capability and capacity building activities to reduce their risks from disasters and natural hazards.
FEMA Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Discussed support for amending the definition of building codes as used in determining eligible permanent work under proposed section 409 to include electric power utility standards in H.R. 4669, the FEMA Act. Discussed concerns with possible changes to the Stafford Act to allow the recoupment of recovery costs. Discussed the impact to public power utilities of Building Resilient Infrastructure and Communities grant cancellations.
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
SPEED Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under NEPA (all provisions). Discussed support of reforms to the Endangered Species Act that would change the definition of habitat (no legislation). Discussed how the Endangered Species Act impacts energy infrastructure projects (no legislation). Discussed H.R. 1897, the Endangered Species Act Amendments of 2025 (all provisions). Discussed the importance of the Endangered Species Act for public power utilities and some of the challenges the statute creates (Docket No. FWS-HQ-ES-2025-0039, FWS-HQ-ES-2025-0048, FWS-HQ-ES-2025-0029, and FWS-HQ-ES-2025-0044).
AI Fraud Accountability Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Southwestern Power Administration Fund Establishment Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for possible legislation to amend 26 USC 6417, elective payment of energy tax credits. Discussed opposition to possible guidance superseding IRS Notice 2013-29, defining beginning of construction for purposes of designating a qualifying facility for certain clean energy projects. Discussed support of possible guidance relating to 26 USC 45U, existing nuclear tax credit, and 26 USC 7701(51)(a), prohibited foreign entity debt test. Discussed the need for the Treasury Department to issue 45U tax guidance for existing nuclear tax credits (no legislation). Discussed possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for possible regulations to implement section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for possible regulations to 26 USC 6417, elective payment of energy tax credits. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for possible legislation to waiver 2 USC 20A, Statutory Pay-as-You-Go, in relation to the budget effects of P.L. 119-21, the One Big, Beautiful Bill Act of 2025.
POWER Act of 2025
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for S. 1429/H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities. Discussed opposition to the repeal of the Stafford Act (no legislation). Provided feedback to draft legislation, the Fixing Emergency Management for Americans (FEMA) Act, including section 101, to replace existing section 406 cost-based grants with new Stafford Act section 409 estimate-based grants.
Fix Our Forests Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
LOCAL Infrastructure Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from the Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025). Discussed opposition to Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025) section 70513(b) (restrictions relating to prohibited foreign entities) provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to H.R. 1, section 70513(b) (restrictions relating to prohibited foreign entities) as passed by the House, provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to section 70512(f), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, and section 70513(a), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, in Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed Elective Pay Blueprint APPA developed for APPA members to guide them on energy tax credits. Discussed support for S. 1481, the LOCAL Infrastructure Act, to reinstate advance refunding bonds. Discussed support for S. 5212, the Enhanced Energy Recovery Act, provisions ensuring tax credits for expanding carbon capture are available via elective payment.
Help Hoover Dam Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
CIRCUIT Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
CIRCUIT Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
GRID Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
GRID Power Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Port Modernization and Supply Chain Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Port Modernization and Supply Chain Protection Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
Basin Fund Preservation Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed impacts staff reductions could have on the operations of the federal Power Marketing Administrations. Discussed support for S. 887, the Basin Fund Preservation Act to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund (all provisions).
Guam Emergency Alert System Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Guam Emergency Alert System Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed potential legislation regarding the Energy Threat Analysis Center and obstacles to increased public power participation. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the urgent need for a replacement for the public disclosure exemptions that were provided under the Critical Infrastructure Partnership Advisory Council to facilitate information sharing at Electricity Subsector Coordinating Council meetings (no legislation). Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for S. 1337, the Cybersecurity Information Sharing Extension Act (all provisions). Discussed support for H.R. 5079, the Widespread Information Management for the Welfare of Infrastructure and Government Act (all provisions). Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed support of H.R. 3657, the Hydropower Licensing Transparency Act, to direct the Federal Energy Regulatory Commission (FERC) to report annually to Congress on the status of the relicensing process for each application for a renewed hydropower dam license. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, from the 118th Congress, which would have expanded the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would have exempted Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed grid-enhancing technologies (GETS) and interconnection queue reform. Also discussed the need to ensure savings related to GETS benefits public power utilities and their customers (no bill). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Provided feedback on a draft bill to create a new must consider provision under section 111(d) of the Public Utility Regulatory Policy Act that would seek to create interconnection procedures to support microgrids. Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions, including issues in Docket AD25-7. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the North American Electric Reliability Corporations (NERC) electric reliability standards development procedures and the impact of FERC Order No. 907 (directing modifications to NERCs critical infrastructure protection standards) on the prioritization of NERCs standards development work. Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Enhanced Energy Recovery Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from the Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025). Discussed opposition to Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025) section 70513(b) (restrictions relating to prohibited foreign entities) provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to H.R. 1, section 70513(b) (restrictions relating to prohibited foreign entities) as passed by the House, provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to section 70512(f), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, and section 70513(a), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, in Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed Elective Pay Blueprint APPA developed for APPA members to guide them on energy tax credits. Discussed support for S. 1481, the LOCAL Infrastructure Act, to reinstate advance refunding bonds. Discussed support for S. 5212, the Enhanced Energy Recovery Act, provisions ensuring tax credits for expanding carbon capture are available via elective payment.
Investing in Our Communities Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change. Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for H.R. 1837, the Investing in Our Communities Act, to restore advance refunding bonds. Discussed support for S. 1453, the Lifting Our Communities through Advanced Liquidity for Infrastructure Act to restore advance refunding bonds. Discussed possible legislation to address domestic content provisions of elective payment of energy tax credits.
FEMA Loan Interest Payment Relief Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act.
FEMA Loan Interest Payment Relief Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for H.R. 9541, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act, to authorize electrical utilities receiving certain financial assistance under the Robert T. Stafford Disaster Relief and Emergency Assistance Act for the restoration of power to also carry out cost-effective hazard mitigation activities. Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance.
Limit, Save, Grow Act of 2023
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change. Discussed section 242 of H.R. 2811, the Limit, Save, Grow Act of 2023, that would repeal the taxpayer election of payments, in lieu of credits, for specified energy property and production of electricity from certain renewable resources. Discussion of concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed Treasury guidance relating to utility assistance use of funding under section 5001 of the CARES Act (Coronavirus State and Local Fiscal Relief Funds) as amended by the Consolidated Appropriations Act of 2020. Discussed support for H.R. 1837, the Investing in Our Communities Act to reinstate the ability to issue tax-exempt advance refunding bonds (all provisions). Discussed support for S. 1453, the Lifting Our Communities through Advance Liquidity for Infrastructure Act (LOCAL Infrastructure Act), to reinstate the ability to issue tax-exempt advance refunding bonds (all provisions). Discussed support for potential legislation to increase the small-issuer exception from $10 million to $30 million. Discussed concerns with Proposed Rule: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election to Treat Clean Hydrogen Production Facilities as Energy Property (88 FR 8920, REG-117631-23 (additionality requirements for clean power used to generate hydrogen).
Hydropower Clean Energy Future Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed possible funding for the Department of Energy (DOE) to assist manufacturers of distribution transformers in increasing their production (no legislation). Discussed the patchwork of cyber incident reporting requirements and concerns about harmonization, including the Cybersecurity and Infrastructure Security Agencys implementation of the Cyber Incident Reporting for Critical Infrastructure Act (CISA-2022-0010). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey. Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Provided feedback on draft legislation, the Rural Grid Resilience Act, to promote microgrids and grid resilience in rural communities. Discussed the price spike in PJMs 2024 Base Residual Auction and efforts by stakeholders to postpone PJMs 2025 Base Residual Auction. Discussed how the Federal Energy Regulatory Commissions (FERC) regulations impact public power communities despite most public power utilities not being subject to FERC ratemaking regulation. Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs. Discussed concerns regarding the long lead times to interconnect new generation resources, and support for policies that prioritize interconnection for load-serving entities.
Hydropower Clean Energy Future Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed support for S. 3627, the Distribution Transformer Efficiency and Supply Chain Reliability Act of 2024 (all provisions). Discussed the need for the FAQS for the Fiscal Years 2022-2023 Funding Cycle for the Department of Energy's Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107) to be clarified regarding eligibility for joint action agencies. Discussed support for DOE's GRIP Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 6185, the Guaranteeing Reliable Infrastructure Development (GRID) Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed making transmission investment tax credits refundable in CETA, direct pay tax credits. Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed concerns with amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues across the U.S. Discussed the development of Western markets. Discussed President Bidens Executive Order to promote the safe, secure, and trustworthy development and use of artificial intelligence (AI). Discussed the potential use of AI by electric utilities. Discussed the National Cyber Incident Response Plan. Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Also discussed concerns with how the federal permitting process is slowing the ability of NTUA and volunteers to connect additional Navajo Nation homes to the electric grid.
Hydropower Clean Energy Future Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.
Protecting America’s Distribution Transformer Supply Chain Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.
Protecting America’s Distribution Transformer Supply Chain Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed support for S. 3627, the Distribution Transformer Efficiency and Supply Chain Reliability Act of 2024 (all provisions). Discussed the need for the FAQS for the Fiscal Years 2022-2023 Funding Cycle for the Department of Energy's Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107) to be clarified regarding eligibility for joint action agencies. Discussed support for DOE's GRIP Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 6185, the Guaranteeing Reliable Infrastructure Development (GRID) Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed making transmission investment tax credits refundable in CETA, direct pay tax credits. Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed concerns with amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues across the U.S. Discussed the development of Western markets. Discussed President Bidens Executive Order to promote the safe, secure, and trustworthy development and use of artificial intelligence (AI). Discussed the potential use of AI by electric utilities. Discussed the National Cyber Incident Response Plan. Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Also discussed concerns with how the federal permitting process is slowing the ability of NTUA and volunteers to connect additional Navajo Nation homes to the electric grid.
BIG WIRES Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.
BIG WIRES Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed support for S. 3627, the Distribution Transformer Efficiency and Supply Chain Reliability Act of 2024 (all provisions). Discussed the need for the FAQS for the Fiscal Years 2022-2023 Funding Cycle for the Department of Energy's Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107) to be clarified regarding eligibility for joint action agencies. Discussed support for DOE's GRIP Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 6185, the Guaranteeing Reliable Infrastructure Development (GRID) Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed making transmission investment tax credits refundable in CETA, direct pay tax credits. Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed concerns with amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues across the U.S. Discussed the development of Western markets. Discussed President Bidens Executive Order to promote the safe, secure, and trustworthy development and use of artificial intelligence (AI). Discussed the potential use of AI by electric utilities. Discussed the National Cyber Incident Response Plan. Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Also discussed concerns with how the federal permitting process is slowing the ability of NTUA and volunteers to connect additional Navajo Nation homes to the electric grid.
Grid Resiliency Tax Credit Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change. Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed the likelihood of legislation to amend the tax treatment of municipal bonds. Discussed implementation of 26 USC 45U, the existing nuclear tax credit. Discussed support for direct pay of the nuclear investment tax credit (P.L. 117-169, sec. 13105). Discussed support for adding direct pay to S. 1793/H.R. 5803, the Grid Resiliency Tax Credit Act. Discussed possible changes to the three-year limit on customized commercial contracts under 16 CFR 1.141-7(f)(3) - private use rules for output facilities financed with tax-exempt bonds.
GRID Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed support for S. 3627, the Distribution Transformer Efficiency and Supply Chain Reliability Act of 2024 (all provisions). Discussed the need for the FAQS for the Fiscal Years 2022-2023 Funding Cycle for the Department of Energy's Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107) to be clarified regarding eligibility for joint action agencies. Discussed support for DOE's GRIP Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 6185, the Guaranteeing Reliable Infrastructure Development (GRID) Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed making transmission investment tax credits refundable in CETA, direct pay tax credits. Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed concerns with amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues across the U.S. Discussed the development of Western markets. Discussed President Bidens Executive Order to promote the safe, secure, and trustworthy development and use of artificial intelligence (AI). Discussed the potential use of AI by electric utilities. Discussed the National Cyber Incident Response Plan. Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Also discussed concerns with how the federal permitting process is slowing the ability of NTUA and volunteers to connect additional Navajo Nation homes to the electric grid.
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2023
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed possible funding for the Department of Energy (DOE) to assist manufacturers of distribution transformers in increasing their production (no legislation). Discussed the patchwork of cyber incident reporting requirements and concerns about harmonization, including the Cybersecurity and Infrastructure Security Agencys implementation of the Cyber Incident Reporting for Critical Infrastructure Act (CISA-2022-0010). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey. Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Provided feedback on draft legislation, the Rural Grid Resilience Act, to promote microgrids and grid resilience in rural communities. Discussed the price spike in PJMs 2024 Base Residual Auction and efforts by stakeholders to postpone PJMs 2025 Base Residual Auction. Discussed how the Federal Energy Regulatory Commissions (FERC) regulations impact public power communities despite most public power utilities not being subject to FERC ratemaking regulation. Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs. Discussed concerns regarding the long lead times to interconnect new generation resources, and support for policies that prioritize interconnection for load-serving entities.
Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2023
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.
Clean Electricity and Transmission Acceleration Act of 2023
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.
Clean Electricity and Transmission Acceleration Act of 2023
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed support for S. 3627, the Distribution Transformer Efficiency and Supply Chain Reliability Act of 2024 (all provisions). Discussed the need for the FAQS for the Fiscal Years 2022-2023 Funding Cycle for the Department of Energy's Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107) to be clarified regarding eligibility for joint action agencies. Discussed support for DOE's GRIP Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 6185, the Guaranteeing Reliable Infrastructure Development (GRID) Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed making transmission investment tax credits refundable in CETA, direct pay tax credits. Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed concerns with amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues across the U.S. Discussed the development of Western markets. Discussed President Bidens Executive Order to promote the safe, secure, and trustworthy development and use of artificial intelligence (AI). Discussed the potential use of AI by electric utilities. Discussed the National Cyber Incident Response Plan. Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Also discussed concerns with how the federal permitting process is slowing the ability of NTUA and volunteers to connect additional Navajo Nation homes to the electric grid.
Federal Bureau of Prisons Voting Assistance Act of 2023
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed Columbia River Settlement Agreement and concerns with the potential impact of breaching the Lower Snake River dams on hydropower production, meeting clean energy goals, and grid reliability (no legislation). Discussed Columbia River Treaty negotiations. Discussed support for S. 3581/H.R. 6924, the Hydropower Delivery Rate-reduction Offset (HYDRO) Act. Discussed the issue of the assignment of inequitable costs by the Army Corps of Engineers to the Power Marketing Administrations and their customers. Discussed support for ensuring the Water Resources Development Act (no bill number) protects federal hydropower customers from costs issued by the Army Corps of Engineers for which they receive no benefit. Discussed language to make clear that the Power Marketing Administration Administrators retain full authority on setting rates in draft Water Resources Development Act legislation. Discussed the importance of preserving Power Marketing Administration rate making authority; the application of dam safety costs to state-of-the-art modifications; the Stockton Lake compromise on water supply and hydropower generation; and the study of power deauthorization at Willamette Valley projects in the context of future Water Resource Development Act legislation (no bill). Discussed concerns with sections 121(a) and 121(c) of H.R. 8812, the Water Resources Development Act, regarding the classification of authorized purposes at Corps projects and cost sharing. Also discussed an amendment to the legislation to create a pilot program for Corps projects in AZ, CA, and NV at which the secretary of the Army to declare water supply is an authorized purpose during drought emergencies. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities. Discussed growing threats to electric utilities from wildfires (no legislation). Discussed S. 4628, the Enhancing Mitigation and Building Effective Resilience Act (all provisions). Discussed H.R. 8160, the Breaking Irresponsible Energy and Commercial Habitats Act (all provisions). Discussed H.R. 8161, the Electric Ratepayer Funding Alternative Act (all provisions). Discussed H.R. 8159, the Abandoning Inconsistent and Rash Environmental Solutions Act (all provisions). Discussed H.R. 8156, the Queries Act (all provisions).
Creating Confidence in Clean Water Permitting Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.
Creating Confidence in Clean Water Permitting Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed support for S. 3627, the Distribution Transformer Efficiency and Supply Chain Reliability Act of 2024 (all provisions). Discussed the need for the FAQS for the Fiscal Years 2022-2023 Funding Cycle for the Department of Energy's Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107) to be clarified regarding eligibility for joint action agencies. Discussed support for DOE's GRIP Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 6185, the Guaranteeing Reliable Infrastructure Development (GRID) Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed making transmission investment tax credits refundable in CETA, direct pay tax credits. Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed concerns with amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues across the U.S. Discussed the development of Western markets. Discussed President Bidens Executive Order to promote the safe, secure, and trustworthy development and use of artificial intelligence (AI). Discussed the potential use of AI by electric utilities. Discussed the National Cyber Incident Response Plan. Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Also discussed concerns with how the federal permitting process is slowing the ability of NTUA and volunteers to connect additional Navajo Nation homes to the electric grid.
SPEED and Reliability Act of 2024
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.
To direct the Comptroller General of the United States to submit to Congress an updated report on the roles, responsibilities, and practices of the Council on Environmental Quality.
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed Columbia River Settlement Agreement and concerns with the potential impact of breaching the Lower Snake River dams on hydropower production, meeting clean energy goals, and grid reliability (no legislation). Discussed Columbia River Treaty negotiations. Discussed support for S. 3581/H.R. 6924, the Hydropower Delivery Rate-reduction Offset (HYDRO) Act. Discussed the issue of the assignment of inequitable costs by the Army Corps of Engineers to the Power Marketing Administrations and their customers. Discussed support for ensuring the Water Resources Development Act (no bill number) protects federal hydropower customers from costs issued by the Army Corps of Engineers for which they receive no benefit. Discussed language to make clear that the Power Marketing Administration Administrators retain full authority on setting rates in draft Water Resources Development Act legislation. Discussed the importance of preserving Power Marketing Administration rate making authority; the application of dam safety costs to state-of-the-art modifications; the Stockton Lake compromise on water supply and hydropower generation; and the study of power deauthorization at Willamette Valley projects in the context of future Water Resource Development Act legislation (no bill). Discussed concerns with sections 121(a) and 121(c) of H.R. 8812, the Water Resources Development Act, regarding the classification of authorized purposes at Corps projects and cost sharing. Also discussed an amendment to the legislation to create a pilot program for Corps projects in AZ, CA, and NV at which the secretary of the Army to declare water supply is an authorized purpose during drought emergencies. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities. Discussed growing threats to electric utilities from wildfires (no legislation). Discussed S. 4628, the Enhancing Mitigation and Building Effective Resilience Act (all provisions). Discussed H.R. 8160, the Breaking Irresponsible Energy and Commercial Habitats Act (all provisions). Discussed H.R. 8161, the Electric Ratepayer Funding Alternative Act (all provisions). Discussed H.R. 8159, the Abandoning Inconsistent and Rash Environmental Solutions Act (all provisions). Discussed H.R. 8156, the Queries Act (all provisions).
ACRES Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed Columbia River Settlement Agreement and concerns with the potential impact of breaching the Lower Snake River dams on hydropower production, meeting clean energy goals, and grid reliability (no legislation). Discussed Columbia River Treaty negotiations. Discussed support for S. 3581/H.R. 6924, the Hydropower Delivery Rate-reduction Offset (HYDRO) Act. Discussed the issue of the assignment of inequitable costs by the Army Corps of Engineers to the Power Marketing Administrations and their customers. Discussed support for ensuring the Water Resources Development Act (no bill number) protects federal hydropower customers from costs issued by the Army Corps of Engineers for which they receive no benefit. Discussed language to make clear that the Power Marketing Administration Administrators retain full authority on setting rates in draft Water Resources Development Act legislation. Discussed the importance of preserving Power Marketing Administration rate making authority; the application of dam safety costs to state-of-the-art modifications; the Stockton Lake compromise on water supply and hydropower generation; and the study of power deauthorization at Willamette Valley projects in the context of future Water Resource Development Act legislation (no bill). Discussed concerns with sections 121(a) and 121(c) of H.R. 8812, the Water Resources Development Act, regarding the classification of authorized purposes at Corps projects and cost sharing. Also discussed an amendment to the legislation to create a pilot program for Corps projects in AZ, CA, and NV at which the secretary of the Army to declare water supply is an authorized purpose during drought emergencies. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities. Discussed growing threats to electric utilities from wildfires (no legislation). Discussed S. 4628, the Enhancing Mitigation and Building Effective Resilience Act (all provisions). Discussed H.R. 8160, the Breaking Irresponsible Energy and Commercial Habitats Act (all provisions). Discussed H.R. 8161, the Electric Ratepayer Funding Alternative Act (all provisions). Discussed H.R. 8159, the Abandoning Inconsistent and Rash Environmental Solutions Act (all provisions). Discussed H.R. 8156, the Queries Act (all provisions).
Breaking Irresponsible Energy and Commercial Habits Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed Columbia River Settlement Agreement and concerns with the potential impact of breaching the Lower Snake River dams on hydropower production, meeting clean energy goals, and grid reliability (no legislation). Discussed Columbia River Treaty negotiations. Discussed support for S. 3581/H.R. 6924, the Hydropower Delivery Rate-reduction Offset (HYDRO) Act. Discussed the issue of the assignment of inequitable costs by the Army Corps of Engineers to the Power Marketing Administrations and their customers. Discussed support for ensuring the Water Resources Development Act (no bill number) protects federal hydropower customers from costs issued by the Army Corps of Engineers for which they receive no benefit. Discussed language to make clear that the Power Marketing Administration Administrators retain full authority on setting rates in draft Water Resources Development Act legislation. Discussed the importance of preserving Power Marketing Administration rate making authority; the application of dam safety costs to state-of-the-art modifications; the Stockton Lake compromise on water supply and hydropower generation; and the study of power deauthorization at Willamette Valley projects in the context of future Water Resource Development Act legislation (no bill). Discussed concerns with sections 121(a) and 121(c) of H.R. 8812, the Water Resources Development Act, regarding the classification of authorized purposes at Corps projects and cost sharing. Also discussed an amendment to the legislation to create a pilot program for Corps projects in AZ, CA, and NV at which the secretary of the Army to declare water supply is an authorized purpose during drought emergencies. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities. Discussed growing threats to electric utilities from wildfires (no legislation). Discussed S. 4628, the Enhancing Mitigation and Building Effective Resilience Act (all provisions). Discussed H.R. 8160, the Breaking Irresponsible Energy and Commercial Habitats Act (all provisions). Discussed H.R. 8161, the Electric Ratepayer Funding Alternative Act (all provisions). Discussed H.R. 8159, the Abandoning Inconsistent and Rash Environmental Solutions Act (all provisions). Discussed H.R. 8156, the Queries Act (all provisions).
Electric Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed Columbia River Settlement Agreement and concerns with the potential impact of breaching the Lower Snake River dams on hydropower production, meeting clean energy goals, and grid reliability (no legislation). Discussed Columbia River Treaty negotiations. Discussed support for S. 3581/H.R. 6924, the Hydropower Delivery Rate-reduction Offset (HYDRO) Act. Discussed the issue of the assignment of inequitable costs by the Army Corps of Engineers to the Power Marketing Administrations and their customers. Discussed support for ensuring the Water Resources Development Act (no bill number) protects federal hydropower customers from costs issued by the Army Corps of Engineers for which they receive no benefit. Discussed language to make clear that the Power Marketing Administration Administrators retain full authority on setting rates in draft Water Resources Development Act legislation. Discussed the importance of preserving Power Marketing Administration rate making authority; the application of dam safety costs to state-of-the-art modifications; the Stockton Lake compromise on water supply and hydropower generation; and the study of power deauthorization at Willamette Valley projects in the context of future Water Resource Development Act legislation (no bill). Discussed concerns with sections 121(a) and 121(c) of H.R. 8812, the Water Resources Development Act, regarding the classification of authorized purposes at Corps projects and cost sharing. Also discussed an amendment to the legislation to create a pilot program for Corps projects in AZ, CA, and NV at which the secretary of the Army to declare water supply is an authorized purpose during drought emergencies. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities. Discussed growing threats to electric utilities from wildfires (no legislation). Discussed S. 4628, the Enhancing Mitigation and Building Effective Resilience Act (all provisions). Discussed H.R. 8160, the Breaking Irresponsible Energy and Commercial Habitats Act (all provisions). Discussed H.R. 8161, the Electric Ratepayer Funding Alternative Act (all provisions). Discussed H.R. 8159, the Abandoning Inconsistent and Rash Environmental Solutions Act (all provisions). Discussed H.R. 8156, the Queries Act (all provisions).
Farm, Food, and National Security Act of 2024
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed general support for the concepts included in draft legislation, the Rural Economic Development Loan Program Collateral Flexibility Act of 2024, and similar language in H.R. 8467, the Farm, Food, and National Security Act of 2024, to give the U.S. Department of Agriculture more flexibility to accept alternative forms of collateral for the Rural Economic Development Loan & Grant Program.
Water Resources Development Act of 2024
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed Columbia River Settlement Agreement and concerns with the potential impact of breaching the Lower Snake River dams on hydropower production, meeting clean energy goals, and grid reliability (no legislation). Discussed Columbia River Treaty negotiations. Discussed support for S. 3581/H.R. 6924, the Hydropower Delivery Rate-reduction Offset (HYDRO) Act. Discussed the issue of the assignment of inequitable costs by the Army Corps of Engineers to the Power Marketing Administrations and their customers. Discussed support for ensuring the Water Resources Development Act (no bill number) protects federal hydropower customers from costs issued by the Army Corps of Engineers for which they receive no benefit. Discussed language to make clear that the Power Marketing Administration Administrators retain full authority on setting rates in draft Water Resources Development Act legislation. Discussed the importance of preserving Power Marketing Administration rate making authority; the application of dam safety costs to state-of-the-art modifications; the Stockton Lake compromise on water supply and hydropower generation; and the study of power deauthorization at Willamette Valley projects in the context of future Water Resource Development Act legislation (no bill). Discussed concerns with sections 121(a) and 121(c) of H.R. 8812, the Water Resources Development Act, regarding the classification of authorized purposes at Corps projects and cost sharing. Also discussed an amendment to the legislation to create a pilot program for Corps projects in AZ, CA, and NV at which the secretary of the Army to declare water supply is an authorized purpose during drought emergencies. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities. Discussed growing threats to electric utilities from wildfires (no legislation). Discussed S. 4628, the Enhancing Mitigation and Building Effective Resilience Act (all provisions). Discussed H.R. 8160, the Breaking Irresponsible Energy and Commercial Habitats Act (all provisions). Discussed H.R. 8161, the Electric Ratepayer Funding Alternative Act (all provisions). Discussed H.R. 8159, the Abandoning Inconsistent and Rash Environmental Solutions Act (all provisions). Discussed H.R. 8156, the Queries Act (all provisions).
ZZZ’s to A’s Act
Client: AMERICAN PUBLIC POWER ASSOCIATION · Firm: AMERICAN PUBLIC POWER ASSOCIATION
Discussed support for funding for the Low Income Home Energy Assistance Program in H.R. 9029, the Labor, Health, and Human Services, and Education, and Related Agencies, 2025 Appropriations Act. Discussed support for funding through the appropriations for DOE to help address labor and materials shortages for distribution transformers (report language H.R. 8897, the Fiscal Year 2025 Energy and Water Development and Related Agencies Appropriations Bill. Discussed concerns with amendment 2 to H.R. 8997, the Fiscal Year 2025 Energy and Water Development and Related Agencies Appropriations Bill. Discussed concerns with provisions curtailing elective payment in potential budget reconciliation legislation. Discussed the possible waiver of the sequestration provisions of the Statutory Pay as You Go Act (2 USC 931) as relates to the American Rescue Plan Act (P.L. 117-7). Expressed concerns with amendments 108 and 89 to the Labor, Health and Human Services, and Related Agencies Fiscal Year 2025 Appropriations bill, to take money from the Low Income Home Energy Assistance Program to create a water assistance program.
Discussed support for regulations implementing 26 USC 7701(51)(D)(i)(I)(dd) regarding the prohibited foreign entity debt test (15 percent) to exempt publicly offered debt or stipulate that the underwriter of publicly offered debt is the issuee for purposes of the text. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts and acquisition of existing output facilities to serve large load customers. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817). Discussed potential changes to 26 USC 6417, elective payment energy tax credits, including unspecified changes to the domestic content requirements for elective payment imposed under sections 48E (investment tax credit) and 45Y (production tax credit). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed the importance of municipal bonds, which are used by public power utilities to build energy infrastructure. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million. Discussed support for S. 5453, the Grid Resiliency Tax Credit Act, to amend the Internal Revenue Code to establish a tax credit for the installation of regionally significant electric power transmission lines. Discussed the potential effect of energy and natural gas prepayment transactions on tax-exempt financing.
Filing targets: Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, Securities & Exchange Commission (SEC)
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2026 · second_quarter · Q2
Discussed support for H.R. 7266, the Rural and Municipal Utility Cybersecurity Act (all provisions) to reauthorize the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed the need to amend sections 4(e) and 18 of the Federal Power Act so that mandatory conditions and fishway prescriptions address only direct project effects, like those from the construction, operation, or maintenance of the licensed project (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed support for H.R. 9337, the Hydropower Licensing Affordability Act, to amend the Federal Power Act to modernize the hydropower licensing process (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities under section 201(f) of the Federal Power Act. Discussed how interregional transmission planning should be left to each region of the country rather than imposing a one-size-fits-all federal mandate for each region to maintain a minimum level of transfer capability with its neighbors (no legislation). Discussed maintaining the existing beneficiary-pays cost allocation principle for transmission under the Federal Power Act to require the costs of a transmission project to be allocated to beneficiaries in a way that is roughly commensurate with the estimated benefits (no legislation). Discussed general support for legislation that would remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative National Environmental Policy Act requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed H.R. 6633, the High-Capacity Grid Act (all provisions), to establish a best-available transmission conductor standard for certain transmission projects under the Federal Power Act and to provide for presumptions regarding cost recovery for such conductors. Discussed support for H.R. 3616/S. 3034, the Reliable Power Act, to give the Federal Energy Regulatory Commission the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 9332, the Load Forecasting Enhancement Act, to require the Federal Energy Regulatory Commission to establish regional joint boards to study electric load forecasting. Discussed technical assistance for public power utilities for load forecasting. Discussed H.R. 9340, the Ratepayer Protection Act, to amend the Public Utility Regulatory Policies Act of 1978 to establish a federal standard relating to the recovery of the full, incremental costs of upgrades that serve large-load customers (all provisions). Discussed Winter Storm Fern and the use of section 202(c) orders by the Department of Energy to ensure grid reliability. Discussed grid enhancing technologies and their potential ability to improve grid reliability but should only be deployed where there are clear reliability and consumer benefits (no legislation). Discussed support for joint ownership of transmission facilities to help facilitate transmission development while keeping costs affordable for electricity customers (no legislation). Provided feedback on draft transmission legislation to make changes to the Federal Power Act that would, among other things, expand the Federal Energy Regulatory Commissions authority over public power utilities and increase costs for their customers. Provided feedback on draft legislation, the State Energy Oversight Act, on performance-based ratemaking. Discussed the need for permitting reform efforts to be technology neutral (no bill). Discussed support for H.R. 8308, the Create Expedited Reviews to Transform American Infrastructure Now (CERTAIN) Act, to reduce permitting delays and create a more predictable environment for infrastructure development (all provisions). Discussed the importance of coordination between the military and public power utilities that serve them (no legislation). Discussed issues related to defense critical electric infrastructure, including the importance of coordination between the military and Department of Energy (no legislation). Discussed existing cooperative agreements with the Department of Energy (DE-CR0000007, DE-CR0000015, and DE-CR0000026. Discussed the Executive Order on Artificial Intelligence. Discussion of distribution transformer supply chain challenges (no legislation). Discussed the impact of federal trade policies on supply chains for public power utilities (no legislation). Discussed supply chain issues facing public power utilities and the significant cost increases they are seeing for key electrical equipment that can only be acquired abroad (no legislation). Discussed the importance of the Tennessee Valley Authority to public power utilities served by it. Discussed the public power business model (no legislation). Discussed energy affordability and all the actions public power utilities take to keep electricity affordable for their customers and to assist those in need (no legislation). Discussed how public power utilities are working to ensure their customers do not bear the costs of serving large computational loads (no legislation). Discussed issues related to data center affordability and support for efforts to protect affordability and reliability, as well as ensuring a voice for public power in evaluating governance issues (FERC Docket RM26-4 and AD26-7). Discussed strategies to address the growing burden of transmission costs, including joint ownership and the elimination of transmission incentives.
Discussed concerns with proposed changes to the operation of the Federal Emergency Management Agency (FEMA) as proposed by the FEMA Reform Council in its Final Report (changes to disaster designation methodology, public assistance calculations, and converting public assistance into block grants). Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure.
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support for regulations implementing 26 USC 7701(51)(D)(i)(I)(dd) regarding the prohibited foreign entity debt test (15 percent) to exempt publicly offered debt or stipulate that the underwriter of publicly offered debt is the issuee for purposes of the text. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts and acquisition of existing output facilities to serve large load customers. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817). Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for simplifying the qualification for elective payment under 26 USC 6417 (no legislation). Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed the importance of municipal bonds, which are used by public power utilities to build energy infrastructure. Discussed support for S. 1481, the Lifting Our Communities through Advanced Liquidity for Infrastructure Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million. Discussed opposition to proposed changes to tax-exempt financing to encourage the privatization of public infrastructure through asset recycling (no legislation). Discussed the potential effect of energy and natural gas prepayment transactions on tax-exempt financing.
Discussed support for increased funding for the Low Income Home Energy Assistance Program and efforts to ensure the timely disbursement of funds to states (LIHEAP)(no legislation). Discussed support for section 4 of H.R. 7147, the Homeland Security and Further Additional Continuing Appropriations Act, 2026, which incorporates by reference the Joint Explanatory Statement that prescribes Federal Emergency Management Agency actions regarding disaster designations, BRIC grants, public assistance payments, and staffing.
Filing targets: Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Intl Trade Administration (ITA), Office of Management & Budget (OMB), SENATE, Securities & Exchange Commission (SEC), Treasury, Dept of, U.S. Forest Service
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2026 · first_quarter · Q1
Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act of 2025, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities.
Discussed possible regulations to implement section 26 USC 7701(a)(51)(D)(i)(l)(dd), prohibited foreign entity debt test (15 percent). Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for elective payment of energy tax credits in the Inflation Reduction Act (26 USC 6817) and the need for clarity from the Treasury Department on the implementation of section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for H.R. 1255, the Investing in Our Communities Act, legislation that would enable public power utilities to better manage the debt they use to finance critical infrastructure investments (all provisions). Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed support for potential legislation to increase the $10 million small issue threshold in 26 USC 265(b)(3) to $30 million.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Forest Service, White House Office
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2025 · fourth_quarter · Q4
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reauthorizing the Rural and Municipal Utility Grant and Technical Assistance (RMUC) Program as authorized in section 40124 of the Infrastructure Investment and Jobs Act of 2021. Also discussed extending the availability of existing funds and qualifications for awards. Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed general APPA support for hydropower licensing and relicensing reform, including amending section 4(e) of the Federal Power Act (16 USC ch. 12) to limit mandatory conditions and fishway prescriptions and section 241 of the Energy Policy Act of 2005 (P.L. 109-58) to extend trial-type hearing rights to alternative conditions under section 33 of the Federal Power Act (no legislation). Discussed support for S. 3518, the Fair Licensing for Operations of Water Structures (FLOWS) Act of 2025, to amend the Federal Power Act to address certain alterations in, and the maintenance and repair of, project works, to provide for the licensing of micro hydrokinetic energy projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed support for H.R. 3616, the Reliable Power Act, to give the Federal Energy Regulatory Commission (FERC) the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Discussed H.R. 3843, the Baseline Reliability Protection Act (all provisions), to prohibit retirements of baseload electric generating units in any area that is served by a Regional Transmission Organization or an Independent System Operator and that the North American Electric Reliability Corporation categorizes as at elevated risk or high risk of electricity supply shortfalls. Discussed resource adequacy issues and the importance of grid reliability (no legislation). Discussed H.R. 3699, the Energy Choice Act, to prohibit states or local governments from prohibiting or limiting the connection, reconnection, modification, installation, transportation, distribution, or expansion of an energy service based on the type or source of energy to be delivered (all provisions). Discussed how public power utilities, both transmission owners and transmission dependent, interact with FERC, participate in wholesale electricity markets, and other regional planning bodies (no legislation). Discussed the Department of Energys Speed to Power Initiative and the importance of resource adequacy for grid reliability. Discussed the impact tariffs are having on public power utilities (no legislation).
Discussed possible regulations to implement section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support of possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts.
Discussed support for H.R. 3158/S. 1570, the Hoover Dam Act, to amend the Boulder Canyon Project Act to authorize the Secretary of the Interior to expend amounts in the Colorado River Dam fund Discussed the need for the Bureau of Reclamation to release approximately $52 million in the Colorado River Dam Fund for upgrades at Hoover Dam. Discussed the need for appropriate staffing at the Bureau of Reclamation to counter the impacts of staff cuts that have increased overhead rates at Hoover Dam from 12 percent to 41 percent (no legislation). Discussed support for H.R. 471/S. 1462, the Fix Our Forests Act, including section 204 in the House bill to provide categorical exclusion for vegetation management along power line rights-of-way on federal lands. Discussed support for agency actions to expedite environmental reviews under NEPA, the Endangered Species Act, and National Historic Preservation Act to reduce the risk of wildfires. Discussed strict liability caps for wildfires on federal lands under the Forest Land Policy and Management Act (P.L. 94-579). Discussed the need for more consistency of land management practices at federal land management agencies, such as U.S. Forest Service and the Bureau of Land Management. Discussed support for S. 1034/H.R. 2432, the Southwestern Power Administration Fund Establishment Act (all provisions).
Discussed support of possible legislation to waive 2 U.S. Code Chapter 20A, Statutory Pay-as-You-Go, in relation to the budget effects of the One Big Beautiful Bill Act of 2025 (P.L. 119-21). Discussed support for increased funding for the Low Income Home Energy Assistance Program (LIHEAP)(no legislation). Discussed support for a mechanism that provides emergency funding for LIHEAP during government shutdowns (no legislation).
Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Discussed support for amending the definition of building codes as used in determining eligible permanent work under proposed section 409 to include electric power utility standards in H.R. 4669, the FEMA Act. Discussed concerns with possible changes to the Stafford Act to allow the recoupment of recovery costs. Discussed the impact to public power utilities of Building Resilient Infrastructure and Communities grant cancellations.
Discussed support for H.R. 4776, the SPEED Act, to reform permitting processes under NEPA (all provisions). Discussed support of reforms to the Endangered Species Act that would change the definition of habitat (no legislation). Discussed how the Endangered Species Act impacts energy infrastructure projects (no legislation). Discussed H.R. 1897, the Endangered Species Act Amendments of 2025 (all provisions). Discussed the importance of the Endangered Species Act for public power utilities and some of the challenges the statute creates (Docket No. FWS-HQ-ES-2025-0039, FWS-HQ-ES-2025-0048, FWS-HQ-ES-2025-0029, and FWS-HQ-ES-2025-0044).
Discussed support for H.R. 3898, the PERMIT Act, to improve the permitting process for infrastructure projects under the Clean Water Act, the provision regarding nationwide permitting and the determination of the appropriate acreage threshold for discharges into WOTUS, and the provision regarding section 18 statutory exclusion from the regulatory definition of WOTUS for waste treatment systems. Discussed support for H.R. 161, the New Source Review Permitting Improvement Act (all provisions). Discussed the proposed rulemaking to revise the definition of Waters of the United States and implementation changes. Also discussed ways to strengthen the proposal (Docket ID No.: EPA-OW-2025-0322; FRL 11132.1-01-OW).
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of, U.S. Fish & Wildlife Service (USFWS), U.S. Forest Service
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2025 · third_quarter · Q3
Discussed potential legislation regarding the Energy Threat Analysis Center and obstacles to increased public power participation. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the urgent need for a replacement for the public disclosure exemptions that were provided under the Critical Infrastructure Partnership Advisory Council to facilitate information sharing at Electricity Subsector Coordinating Council meetings (no legislation). Discussed CISAs work to implement the Cyber Incident Reporting for Critical Infrastructure Act (passed as Division Y of P.L. 117-103) - provisions regarding the scope of the rulemaking and harmonization of cyber incident reporting with other reporting mandates. Discussed support for S. 1337, the Cybersecurity Information Sharing Extension Act (all provisions). Discussed support for H.R. 5079, the Widespread Information Management for the Welfare of Infrastructure and Government Act (all provisions). Discussed concerns with the creation of additional cyber incident reporting requirements for electric utilities (no legislation). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed support of H.R. 3657, the Hydropower Licensing Transparency Act, to direct the Federal Energy Regulatory Commission (FERC) to report annually to Congress on the status of the relicensing process for each application for a renewed hydropower dam license. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed the need for permitting reform, including changes to the National Environmental Policy Act (NEPA) and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, from the 118th Congress, which would have expanded the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would have exempted Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed general support for legislation that would remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes (no legislation). Discussed H.R. 7786, the SPEED & Reliability Act (all provisions), from the 118th Congress, to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed concerns with H.R. 5600, the SPEED & Reliability Act (all provisions), to remove duplicative NEPA requirements for the National Interest Electric Transmission Corridor designation and siting processes. Discussed grid-enhancing technologies (GETS) and interconnection queue reform. Also discussed the need to ensure savings related to GETS benefits public power utilities and their customers (no bill). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (all provisions). Provided feedback on a draft bill to create a new must consider provision under section 111(d) of the Public Utility Regulatory Policy Act that would seek to create interconnection procedures to support microgrids. Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions, including issues in Docket AD25-7. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the North American Electric Reliability Corporations (NERC) electric reliability standards development procedures and the impact of FERC Order No. 907 (directing modifications to NERCs critical infrastructure protection standards) on the prioritization of NERCs standards development work. Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for possible legislation to amend 26 USC 6417, elective payment of energy tax credits. Discussed opposition to possible guidance superseding IRS Notice 2013-29, defining beginning of construction for purposes of designating a qualifying facility for certain clean energy projects. Discussed support of possible guidance relating to 26 USC 45U, existing nuclear tax credit, and 26 USC 7701(51)(a), prohibited foreign entity debt test. Discussed the need for the Treasury Department to issue 45U tax guidance for existing nuclear tax credits (no legislation). Discussed possible changes to 26 CFR 1.141-7, Special Rules for Output Facilities, to accommodate long-term customized commercial contracts. Discussed support for possible regulations to implement section 26 USC 7701(a)(51), prohibited foreign entity debt test. Discussed support for possible regulations to 26 USC 6417, elective payment of energy tax credits. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed support for possible legislation to waiver 2 USC 20A, Statutory Pay-as-You-Go, in relation to the budget effects of P.L. 119-21, the One Big, Beautiful Bill Act of 2025.
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 2836, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed the need for FEMA reform (no legislation). Provided feedback on draft legislation, the Fixing Emergency Management for Americans (FEMA) Act, including section 101, to replace existing section 406 cost-based grants with new Stafford Act section 409 estimate-based grants and section 301, expanding preapproved hazard mitigation lists to include public power. Also discussed section 117 on expedited funding for emergency work, section 118 to clarify the definition of local in constancy in procurement practices, and section 122 on loan interest payment relief. Discussed support for H.R. 4669, the FEMA Act (all provisions), including section 101 on rebuilding public infrastructure. Provided feedback on draft legislation to reform the Stafford Act to allow for better grid technology when rebuilding downed power lines after a disaster. Discussed the termination of the Building Resilient Infrastructure and Communities program at FEMA, which provides funding to support eligible entities undertaking pre-disaster and hazard mitigation projects or capability and capacity building activities to reduce their risks from disasters and natural hazards.
Filing targets: Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Office of Management & Budget (OMB), SENATE, Treasury, Dept of
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2025 · second_quarter · Q2
Discussed the public power business model. Discussed the role of the Electricity Subsector Coordinating Council (ESCC) and the need for Critical Infrastructure Partnership Advisory Council (CIPAC) protections that allow the ESCC to be operational. Discussed the importance of the Federal Emergency Management Agency (FEMA) in coordinating the response to federal disasters and the restoration of electricity after such disasters. Discussed the upcoming hurricane season and the importance of the Department of Energy (DOE) as a partner in the mutual aid response given federal waivers and exemptions authority primarily resides in the Office of Cybersecurity, Energy Security, and Emergency Response within DOE. Discussed APPAs involvement with the Energy Threat Analysis Center. Discussed support for the reauthorization of the Cybersecurity and Information Security Act of 2015 (passed as Division N of P.L. 114-113) and provisions to maintain public power utilities inclusion in the definition of private entity in section 102(15)(B) and maintaining public power utilities inclusion in section 104(B) - Exemption from Disclosure. Discussed the importance of the Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58) to help smaller public power utilities with their cybersecurity posture. Discussed concerns with proposed rescissions of funding for the RMUC Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed how public power utilities are utilizing the Grid Resilience and Innovation Partnerships (GRIP) Program to enhance grid reliability and affordability in their communities. Discussed APPA support for the GRIP Program and protecting obligated funds from potential rescissions (no legislation). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower to the electric grid and reliability. Discussed support for H.R. 2160/S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed draft appropriations report language for DOE to study the feasibility of federal technical assistance and regional planning to meet local and regional energy goals. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed congressional oversight of the interconnection queue process (no legislation). Discussed the need for more flexibility for Federal Energy Regulatory Commission (FERC) and regional transmission organizations in prioritizing interconnection queues based on regional needs rather than resource attributes. Discussed H.R. 1047/S. 465, the GRID Power Act, to direct FERC to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed support for H.R. 3616, the Reliable Power Act, to give FERC the authority to determine and mitigate the significant reliability impacts of major federal regulations (pre-introduction and post-introduction of legislation). Discussed draft legislation, the State Energy Accountability Act, to create a new Public Utility Regulatory Policies Act (PURPA) section 111(d) must-consider requirement to require state regulatory authorities that implement an intermittent energy policy to considering conducting and making public an evaluation of the policys impact on reliability, including during extreme weather, and affordability, among other impacts. Discussed draft legislation, the State Planning for Reliability and Affordability Act, to require utilities to establish sufficient reliable generation facilities to ensure the availability of electric energy over a 10-year period as part of integrated resource planning. Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed the importance of electricity affordability for all customers (no legislation). Discussed public powers concerns about transmission affordability, including transmission incentives. Discussed FERCs concerns about resource adequacy and the results of recent capacity auctions. Discussed the importance of reliability, including coordination between the gas and electricity sectors. Discussed the impact of changing tariffs on supply chains for electric utilities (no legislation). Discussed the importance of the Tennessee Valley Authority in providing affordable and reliable power to the Tennessee Valley.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2025 · first_quarter · Q1
Discussed the public power business model. Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the implementation of Rural and Municipal Advanced Cybersecurity Grant Technical Assistance Program (section 40124 of the Infrastructure Investment and Jobs Act, P.L. 117-58). Discussed support for S. 448, the Credit Incentives for Resilient Critical Utility Infrastructure and Transformers (CIRCUIT) Act to provide tax credits to the manufacturers of distribution transformers (all provisions). Discussed support for reintroduction of H.R. 4045, the Hydropower Clean Energy Future Act in the 119th Congress (all provisions). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed draft language to not require licensees to obtain approval for non-substantive alterations or additions at hydropower facilities, routine maintenance, or replacement of hydropower projects that are in response to circumstances beyond their reasonable control. (no legislation). Discussed support for S. 1183, the Maintaining and Enhancing Hydroelectricity and River Restoration Act, to establish tax credits environmental and safety upgrades at non-federal hydropower projects (all provisions). Discussed energy tax credits for hydropower (no legislation). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey (no legislation). Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed the need for permitting reform, including changes to the National Environmental Policy Act and other environmental statutes, to help expedite the siting and permitting of energy projects to meet rising electricity demand (no legislation). Discussed interconnection queue reform efforts (no legislation). Discussed H.R. 1047/S. 465, the GRID Power Act to direct the Federal Energy Regulatory Commission to reform the interconnection queue process for the prioritization and approval of certain projects (all provisions). Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs (no legislation). Discussed the importance of maintaining grid reliability and resource adequacy issues. Also discussed of electricity affordability for all customers (no legislation). Discussed the potential impact of federal funding freezes (no legislation). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort.
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2024 · fourth_quarter · Q4
Discussed support for funding for the Low Income Home Energy Assistance Program in H.R. 9029, the Labor, Health, and Human Services, and Education, and Related Agencies, 2025 Appropriations Act. Discussed support for legislation to amend sections 4(d)(4) and 4(d)(5) of the Statutory Pay-as-You-Go-Act of 2010 to reduce the five- and ten-year scorecards to zero and avoid the sequestration of direct payment bond and elective pay tax credit payments. Discussed concerns with chaining as discussed in IRS Notice 2024-27, Request for Comments on Situations in Which a Section 6417(a) Election Could Be Made for Credits Purchased in Transfers Under Section 6418(a). Expressed concerns with S. 3830, the Low Income Household Water Assistance Program (LIHWAP) Establishment Act, to temporarily establish a LIHWAP at the Department of Health and Human Services before transitioning it to the Environmental Protection Agency.
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change. Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for the extension and clarification of IRS Notice 2024-9 section 5 process for attestation of good faith determination of qualification for statutory exception to the domestic content requirements for the elective payment of energy tax credits. Discussed tax credits for hydropower (no legislation).
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2024 · third_quarter · Q3
Discussed support for H.R. 9541, the Promoting Opportunities to Widen Electric Resilience (POWER) Act.
Discussed support for funding for the Low Income Home Energy Assistance Program in H.R. 9029, the Labor, Health, and Human Services, and Education, and Related Agencies, 2025 Appropriations Act. Discussed support for funding through the appropriations for DOE to help address labor and materials shortages for distribution transformers (report language H.R. 8897, the Fiscal Year 2025 Energy and Water Development and Related Agencies Appropriations Bill. Discussed concerns with amendment 2 to H.R. 8997, the Fiscal Year 2025 Energy and Water Development and Related Agencies Appropriations Bill. Discussed concerns with provisions curtailing elective payment in potential budget reconciliation legislation. Discussed the possible waiver of the sequestration provisions of the Statutory Pay as You Go Act (2 USC 931) as relates to the American Rescue Plan Act (P.L. 117-7). Expressed concerns with amendments 108 and 89 to the Labor, Health and Human Services, and Related Agencies Fiscal Year 2025 Appropriations bill, to take money from the Low Income Home Energy Assistance Program to create a water assistance program.
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2024 · second_quarter · Q2
Discussed concerns about the effect on public power utilities as counterparties in derivative transactions with banks as a result of increased capital requirements for large bank transactions with non-publicly traded entities under proposed rule, Regulatory Capital Rule: Large Banking Organizations and Banking Organizations with Significant Trading Activity (Docket ID: OCC-2023-0008, 88 Fed. Reg. 64028 (2023) and proposed rule, Regulatory Capital Rule: Risk-Based Capital Surcharges for Global Systemically Important Bank Holding Companies; System Risk Report (FR Y-15) (Docket No. R-1814, 88 Fed. Reg. 60385).
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act.
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2024 · first_quarter · Q1
Discussed concerns with increased capital requirements for large bank transactions with non-publicly traded entities under proposed rule, Regulatory Capital Rule: Large Banking Organizations and Banking Organizations with Significant Trading Activity (Docket ID: OCC-2023-0008, 88 Fed. Reg. 64028 (2023) and proposed rule, Regulatory Capital Rule: Risk-Based Capital Surcharges for Global Systemically Important Bank Holding Companies; System Risk Report (FR Y-15) (Docket No. R-1814, 88 Fed. Reg. 60385). Discussed potential legislation to allow federal home loan banks to credit enhance municipal bonds.
Discussed the Environmental Protection Agency's proposed rules to regulate greenhouse gas emissions from power plants (EPA-HQ-OAR-2023-0072) and the potential impacts to public power utilities, as well as potential impact on affordability and reliability.
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2023 · fourth_quarter · Q4
Discussed including funding in S. 2443, Energy and Water Development and Related Agencies Appropriations Act, 2024, to address the distribution transformer supply chain crisis. Discussed potential legislation to extend sequestration under the Budget Control Act (no bill). Discussed potential legislation to exempt payments to issuers of direct payment bonds from sequestration under the Budget Control Act. Discussed a proposed amendment to H.R. 4394, the Energy and Water Development and Related Agencies Appropriations Act, 2024, on energy sector cybersecurity.
Discussed the Environmental Protection Agency's proposed rules to regulate greenhouse gas emissions from power plants (EPA-HQ-OAR-2023-0072) and the potential impacts to public power utilities, as well as potential impact on affordability and reliability. Discussed the Environmental Protection Agencys (EPA) Particulate Matter (PM) National Ambient Air Quality Standards (NAAQS) (RIN: 2060-AV52) and the need for the agency to retain the current 12 microgram per cubic meter PM2.5 annual standard. Discussed EPA suspending or deferring its decision on reconsidering the PM NAAQS until 2025.
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2023 · third_quarter · Q3
Discussed support of funding for the Low Income Home Energy Assistance Program in S. 2624, Departments of Labor, Health and Human Services, and Education, and Related Agencies Appropriations Act, 2024, and House Appropriations Committee draft version of same. Discussed funding in draft energy and water appropriations bill for addressing the distribution transformer supply chain crisis. Discussed including funding in S. 2443, Energy and Water Development and Related Agencies Appropriations Act, 2024, to address the distribution transformer supply chain crisis. Discussed the need for relief from the Balanced Budget and Emergency Deficit Control Act of 1985, section 251A(6) (implementing direct spending reductions, i.e., sequestration) due its impact on public power utilities that issued direct payment bonds.
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed concerns with practice by the Army Corps of Engineers to assign costs to Power Marketing Administration customers for which they receive no benefit (no bill). Discussed the importance of the federal Power Marketing Administrations in providing reliable and affordable hydropower to public power utilities. Discussed support for the continued existence and federal ownership of the Power Marketing Administrations and the sale of federally generated hydropower at cost-based rates. Discussed support for S. 1324, the SWPA Fund Establishment Act (all provisions), to establish a fund that the Southwestern Power Administration may use for the operation and maintenance of power transmission facilities and other related expenses.
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2023 · second_quarter · Q2
Discussed support for H.R. 2672/S. 1180, the FEMA Loan Interest Payment Relief Act (all provisions).
Discussed the importance of elective pay refundable energy tax credits for public power investments in clean energy technologies to address climate change. Discussed the implementation of the refundable direct pay tax credit provisions included in the Inflation Reduction Act (P.L. 117-169), including the requirement to meet domestic content rules and the timing of refundable elective pay tax credit elections and returns. Discussed section 242 of H.R. 2811, the Limit, Save, Grow Act of 2023, that would repeal the taxpayer election of payments, in lieu of credits, for specified energy property and production of electricity from certain renewable resources. Discussed the domestic content requirements for elective payment of energy tax credits for Internal Revenue Code section 45 production tax credit (PTC), section 45Y clean electricity PTC, section 48 investment tax credit (ITC), and section 48E clean electricity ITC; and energy community bonus credits created under the Inflation Reduction Act (P.L. 117-169). Discussed the domestic content requirements for Internal Revenue Code (IRC) section 45V(c)(2) definition of clean hydrogen and IRC section 6417 elective payment of energy tax credits (entire provision) created under the Inflation Reduction Act (P.L. 117-169). Discussed the domestic content requirements in the Inflation Reduction Act (IRA) and Build America requirements in the Infrastructure Investment and Job Act, specifically the unique rules that apply to public power and electric cooperatives. Discussed provisions in H.R. 3938, the Build It in America Act, to repeal of clean energy production credit (section 301) and to repeal of clean electricity investment credit (section 302). Discussed the need to restore advance refunding bonds and support for legislation in 117th Congress, the Investing in Our Communities Act (all provisions).
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2023 · first_quarter · Q1
Discussed the importance of direct pay refundable energy tax credits for public power investments in clean energy technologies to address climate change. Discussed the implementation of the refundable direct pay tax credit provisions included in the Inflation Reduction Act (P.L. 117-1), including the requirement to meet domestic content rules and the timing of refundable direct pay tax credit elections and returns. Discussed the need to restore advance refunding bonds and support for legislation in 117th Congress, the Investing in Our Communities Act (all provisions). Discussed support for H.R. 1837, the Investing in Our Communities Act (all provisions), to restore advance refunding bonds. Discussed potential legislation to waive PAYGO sequestration of direct payment bonds and refundable tax credits.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Intl Trade Administration (ITA), Labor, Dept of (DOL), Natl Security Council (NSC), Office of Management & Budget (OMB), SENATE, Transportation, Dept of (DOT), Treasury, Dept of
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2022 · fourth_quarter · Q4
Discussed the need for appropriations for the Defense Production Act to help address the distribution transformer supply chain crisis, Fiscal Year 2023 Energy and Water Appropriations Bill, possible disaster supplemental bill, and Consolidated Appropriations Act, 2023. Discussed potential legislation to wave PAYGO sequestration of direct payment bonds and refundable tax credits. Discussed provision to delay PAYGO sequestration in H.R. 2617, Consolidated Appropriations Act, 2023. Discussed support for including supplemental appropriations for Western Area Power Administration to help address drought in H.R. 2617, Consolidated Appropriations Act, 2023
Discussed the importance of direct pay refundable energy tax credits for public power investments in clean energy technologies to address climate change. Discussed the implementation of the refundable direct pay tax credit provisions included in the Inflation Reduction Act (P.L. 117-1). Discussed potential legislation to wave PAYGO sequestration of direct payment bonds and refundable tax credits. Discussed provision to delay PAYGO sequestration in H.R. 2617, Consolidated Appropriations Act, 2023. Discussed support for S. 2306, Maintaining and Enhancing Hydroelectric and River Restoration Act of 2021 (all provisions).
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2022 · third_quarter · Q3
Discussed the importance of nuclear power to GHG reduction goals and to grid reliability.
Discussed public powers support for legislation to address climate change, including potential legislation to create a clean energy standard and what such legislation would need to include to ensure electricity remains affordable, reliable, and sustainable. Discussed what public power utilities are doing to reduce their greenhouse gas (GHG) emissions. Discussed potential GHG regulations on the power sector under section 111 of the Clean Air Act. Discussed the Environmental Protection Agency's (EPA) proceeding, GHG Emission Guidelines for Existing Sources (RIN 2060-AV10); specifically discussed concerns with coordination of suite of rules impacting the power sector. Also discussed how the direct pay provisions in the Inflation Reduction Act will help public power utilities invest in renewable technologies needed to reduce greenhouse gas emissions. Discussed EPA's proceeding, GHG New Source Performance Standards (2060-AV09); specifically discussed the need for regulatory flexibility to meet new source limits. Also discussed investments in new types of generation technology, such as reciprocating internal combustion engines. Discussed EPA's proceeding, Ozone Federal Implementation Plan (2040-AV51); specifically discussed concerns the proposal could have on bulk power system reliability given the lack of compliance flexibility. Also discussed the cost of emissions allowances. Discussed the need for permitting reform to enable the siting and construction of energy infrastructure. Discussed the Clean Water Act provisions (subtitle B) in the Energy Independence and Security Act of 2022 (no bill number). Provided feedback on S.J. Res 55, A joint resolution providing for congressional disapproval under chapter 8 of title 5, United States Code, of the rule submitted by the Council on Environmental Quality relating to National Environmental Policy Act Implementing Regulations Revisions. Discussed the potential impacts EPAs changes to the coal combustion residuals rule could have on public power utilities. Discussed legislative efforts to address environmental justice issues (no specific bills). Discussed the regulatory uncertainty created by changing rules on Waters of the United States (WOTUS), specifically on the waste treatment exclusion. Discussed revisions to WOTUS (RIN 2040-AG19), including maintaining the waste treatment exclusion. Discussed Steam Electric Effluent Limitation Guidelines (RIN 2040-AG23), including concerns with spending resources to comply with 2020 ELG rule when EPA anticipates changing the requirements before full implementation of 2020 ELG rule can occur. Also discussed setting wastewater discharge requirements for FGD wastewater based on membrane technology.
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2022 · second_quarter · Q2
Discussed the importance of direct pay refundable energy tax credits for public power investments in clean energy technologies to address climate change. Discussed support for the provisions in H.R. 5376, the Build Back Better Act, to make refundable, direct pay energy tax credits available to public power utilities - subtitle F, parts 1 (Renewable Electricity and Reducing Carbon Emissions) and 8 (Incentives for Clean Electricity and Transportation). Discussed S. 986, the Carbon Capture, Utilization, and Storage Tax Credit Amendments Act of 2021 (direct pay provision). Discussed S. 627, the Energy Storage Tax Incentive & Deployment Act (proposed revision to allow for direct payment). Discussed the potential waiver of the deficit effects of the American Rescue Plan Act (Pub. Law 117-2) for purposes of the Pay as You Go Act (Pub. Law 111-39) to avoid sequestration of Build America Bonds payments.
Filing targets: Army, Dept of (Corps of Engineers), Council on Environmental Quality (CEQ), Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Economic Council (NEC), SENATE, White House Office
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2022 · first_quarter · Q1
Discussed support for additional funding for EPAs federal and state coal combustion residuals permit programs in the fiscal year 2023 Interior Appropriations bill (no bill yet). Discussed funding for the Low Income Home Energy Assistance Program in H.R. 4502, the Departments of Labor, Health and Human Services, and Education, and Related Agencies Appropriations Act, 2022.
Discussed concerns with the Federal Communication Commission's 6 GHz Report and Order (Docket/RM: 18-295, 17-183 -- Unlicensed Use of the 6 GHz Band; Expanding Flexible Use in Mid-Band Spectrum Between 3.7 and 24 GHz) and efforts to allow more unlicensed devices to operate in the spectrum band used for critical infrastructure communications. Discussed how electric utilities are using broadband technologies. Discussed the exemption in Section 224 of the Communications Act that precludes Federal Communications Commission (FCC) regulation of public power pole attachments. Expressed opposition to any attempt to repeal or weaken the exemption.
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2021 · fourth_quarter · Q4
Discussed provisions in H.R. 5376, the Build Back Better Act, regarding the book tax on corporate income; support for making refundable, direct pay energy tax credits available to public power utilities; and the inclusion of tax credits for hydropower. Discussed the need for comparable incentives for various energy-related tax credits for public power utilities (i.e., refundable, direct pay tax credits). Discussed support for S. 2306, the Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2021, and its inclusion in the Senate draft of the Build Back Better Act (no bill number). Discussed provisions in H.R. 5376, the Build Back Better Act, on providing Rural Utilities Service loans and grants for renewable energy generation and retirement of debt related to fossil-fuel generation and providing refundable direct payment energy-related tax credits. Also discussed support to include language to reinstate advance refunding bonds and increase the small-issuer exception. Discussed concerns with the sequestration of direct payment bonds, including Build America Bonds. Expressed support for S. 610, the Protecting Medicare & American Farmers from Sequester Cuts Act (non-Medicare budget sequestration provisions to postpone for a year PAYGO sequestration cuts). Discussed Treasury guidance related to the taxation of household assistance provided by the Coronavirus State and Local Fiscal Recovery Funds (Pub. Law 117-2, the American Rescue Plan Act).
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2021 · third_quarter · Q3
Discussed H.R. 5192, the Clean Hydrogen Production and Investment Tax Credit Act, and the need to ensure it is available to public power utilities as a refundable, direct payment tax credit. Discussed concerns with the possible inclusion of language in the draft Infrastructure Investment and Jobs Act, to incentivize the privatization of public assets. Discussed H.R. 4720/S. 2475, the Energy Sector Innovation Tax Credit - provisions related to the transfer of credits by certain public entities. Discussed the need for comparable incentives for various energy-related tax credits for public power utilities. Discussed S. 292, the Clean Energy for America Act, and H.R. 848, the Growing Renewable Energy and Efficiency Now (GREEN) Act of 2021 - provisions relating to direct payment bonds and refundable direct payment tax credit for public power utilities. Also discussed the EV tax credit provisions and the definition of public power. Discussed support for an amendment to S. 2118, the Clean Energy for America Act, on tax credits for hydropower. Provided feedback and support for technical changes to S. 2306, the Maintaining and Enhancing River Restoration Act of 2021. Discussed tax-related provisions in the House Ways & Means Committee portion of the Build Back Better Act (eventually H.R. 5376) on providing Rural Utility Service loans and grants for renewable energy generation and retirement of debt related to fossil-fuel generation; providing refundable direct payment energy-related tax credits; reinstatement of advance refunding bonds; and increasing the small-issuer exception. Discuss the proposed investment tax credit for transmission. Discussed the need to restore advance refunding bonds and support for H.R. 2288, the Investing in Our Communities Act, and S. 479, the LOCAL Infrastructure Act. Discussed the need to increase the small-issuer exception. Discussed support for H.R. 2634, the Local Infrastructure Financing Tools Act (provision to increase the small-issuer exception). Discussed the need to ease certain private-use restrictions on municipal bonds. Discussed concerns with the sequestration of direct payment bonds, including Build America Bonds. Discussed Treasury guidance related to the taxation of household assistance provided by the Coronavirus State and Local Fiscal Recovery Funds (Pub. Law 117-2, the American Rescue Plan Act).
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2021 · second_quarter · Q2
Discussed potential legislation to provide a investment tax credit for transmission facilities. Discussed potential legislation to incentivize the privatization of public assets. Discussed draft version of the Energy Sector Innovation Tax Credit - provisions related to the transfer of credits by certain public entities. Discussed the availability of energy-related production and investment tax credits to public power utilities under section 45 and 48 of the U.S. Code. Discussed the need for comparable incentives for various energy-related tax credits for public power utilities. Discussed S. 292, the Clean Energy for America Act - provisions relating to direct payment bonds and refundable direct payment tax credit for public power utilities. Also discussed the EV tax credit provisions and the definition of public power. Discussed support for an amendment to S. 2119, the Clean Energy for America Act, on tax credits for hydropower. Provided feedback and support for technical changes to S. 2306, the Maintaining and Enhancing River Restoration Act of 2021. Discussed direct pay provisions for tribes and the definition of governmental entities as taxpayers in the draft and introduced versions of H.R. 848, the Growing Renewable Energy and Efficiency Now (GREEN) Act. Also discussed provisions on tax credit normalization. Discussed legislation from the 116th Congress (H.R. 5409, the Incentivizing New and Valuable Energy Storage Technology Act) to provide a tax credit for energy storage and the need for it to be available to public power utilities. Discussed H.R. 3180, the Renewable Energy Investment Act - specifically refundable direct payment tax credits for public power utilities. Discussed the need to restore advance refunding bonds and support for H.R. 2288, the Investing in Our Communities Act, and S. 479, the LOCAL Infrastructure Act). Discussed the need to increase the small-issuer exception. Discussed H.R. 2634, the Local Infrastructure Financing Tools Act - provisions on increasing the small-issuer exception, to restore advance refunding bonds, and the use of direct payment bond proceeds for purchase power agreements. Provided feedback on H.R. 2482, the Microgrid Act. Discussed provisions to extend the tax credit to public power utilities, definition of qualifying equipment, and interconnection fees. Discussed support for legislation to increase the value of the 45Q tax credit for carbon capture utilization and storage technologies. Discussed the need to ease certain private-use restrictions on municipal bonds.
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2021 · first_quarter · Q1
Discussed draft legislation to protect the supply chain of certain electric grid components. Discussed concerns with potential efforts to impose additional mandatory reporting requirements on electric utilities regarding grid security. Discussed the need for federal funding for public power utilities serving defense critical facilities (i.e., those with defense critical electric infrastructure). Discussed support for language to prevent public disclosure of sensitive critical energy/electric infrastructure information in potential grid security bills. Provided feedback on S. 622, the American Jobs in Energy Manufacturing Act of 2021. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA used the funding to work with its members to improve their cyber hygiene. Discussed APPAs cooperative agreement with the Department of Energy (DE-CR0000007) and how APPA will use funding to help its members develop and deploy active cyber defense on public power operational technology networks. Discussed SolarWinds supply chain compromise. Discussed Executive Order on the Bulk Power System (EO 13920). Discussed APPAs work with the Department of Energy on mutual aid during national emergencies. Discussed COVID-19 vaccine prioritization for electric utility workers. Discussed future coordination with the Department of Energy on grid security issues. Discussed the impact of COVID-19 on public power utilities and how they were dealing with the pandemic from an operational standpoint; discussed what public power utilities are doing on customer shutoffs during the pandemic; discussed draft language to establish a federal moratorium on utility shutoffs; and discussed support for additional funding for the Low Income Home Energy Assistance Program (LIHEAP) in H.R. 1319, the American Rescue Plan Act. Discussed implementation of the Emergency Renters Assistance Program created by the Consolidated Appropriations Act, 2021 (Pub. Law 116-260). Discussed implementation of Community Development Block Grants - CARES Act - funding for assisting utility customers impacted by the COVID-19 pandemic (Pub. Law 116-136). Discussed provisions to extend mandatory paid sick leave and family medical leave payroll tax credits to governmental entities, provisions to provide LIHEAP to renters, and use of LIHEAP funds to pay electric customer arrearages in H.R. 1319, the American Rescue Plan Act. Discussed H.R. 786, the Supporting State and Local Leaders Act, to grant state and local governments access to payroll tax credits for paid emergency and family leave. Discussed fiscal year 2022 funding for LIHEAP (no bill). Discussed the potential inclusion of language to provide financial assistance to public power utilities negatively impacted by customer non-payments due to the COVID-19 in H.R. 1319, the American Rescue Plan Act. Discussed draft legislation, the Maintaining Access to Essential Services During COVID Emergency Act of 2021, to aid electric utilities negatively impacted by customer non-payments due to pandemic. Discussed the impacts of Winter Storm Uri on public power utilities and concerns about cost impacts to public power customers. Discussed request to President Biden to use the Natural Gas Policy Act to declare a natural gas supply emergency and to authorize the Secretary of Energy to exercise delegated authority under section 302 of the act to cap the price for purchases of natural gas from producers of natural gas or other persons to the extent authorized under the law. Discussed APPA Light Up Navajo Project to provide electric service to Navajo Nation families by using mutual aid from public power utilities to build the infrastructure needed to provide service. Discussed the need for hydropower licensing and relicensing reform (no bill) and the importance of any climate or energy legislation recognizing hydropower as a zero-emitting, renewable resource. Discussed he need for full funding for money authorized in the Energy Act of 2020 (which was then included in H.R. 133 the Consolidated Appropriations, 2021), to the Department of Energy for research, development, and demonstration of technologies needed to meet net-zero emission reduction goals. Also discussed provisions in the Energy Act of 2020 on grid modernization and electric vehicles. Discussed community solar issues and possible legislation to spur community solar. Also discussed on-bill financing for roof-top solar installations. Discussed potential energy-related provisions that could be included in an infrastructure package, including ones on transmission and promoting clean energy technologies. Provided feedback on draft legislation, the Energy Transitions Act, to support communities impacted by the closure of coal facilities. Discussed the EV MAP Act (H.R. 8807 in the 116th Congress). Provided feedback on the EV Infrastructure Rebate Act. Discussed the role of public power utilities in helping deploy electric vehicle charging infrastructure. Provided feedback on the definition of public power in H.R. 448, the Energy Resilient Communities Act. Discussed concerns with proposed transmission incentives in Federal Energy Regulatory Commission (FERC) Docket No. RM 20-10, Notice of Proposed Rulemaking on Electric Transmission Incentives Policy Under Section 219 of the Federal Power Act. Discussed support for distributed energy resources opt-in in FERC Order 2222 (Docket No. RM 18-09) on Participation of Distributed Energy Resource Aggregations in Markets Operated by Regional Transmission Organizations and Independent System Operators. Discussed concerns about rising transmission costs and federal-state jurisdiction concerns. Discussed the North American Electric Reliability Corporation (NERC) report on distributed energy resources, NERC standards efficiency review, and the E-ISAC. Discussed FERC Supplemental Notice of Technical Conference on Resource Adequacy in the Evolving Electricity Sector (Docket No. 21-10).
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2020 · fourth_quarter · Q4
Expressed support for H.R. 359/S. 2095, the Enhancing Grid Security through Public-Private Partnerships Act. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed cybersecurity provisions in the Fiscal Year 2021 National Defense Authorization Act (NDAA) (H.R. 6395). Discussed opposition to including language in the final NDAA bill that would require mandatory cyber incident reporting. Discussed grid security coordination between the Department of Energy and Department of Homeland Security. Discussed support for information protection provisions in S. 2094, the Enhancing State Energy Security Planning and Emergency Preparedness Act. Discussed S. 4821, a bill to amend the Homeland Security Act of 2002, to clarify that utility line technicians qualify as emergency response providers. Discussed efforts by the electric utility sector to ensure electric service during the COVID-19 pandemic, including efforts undertaken to protect utility workers, obtain testing for key utility personnel, and the need for personal protective equipment for key utility personnel. Also discussed contact tracing for utilities. Discussed APPAs cooperative agreement with the Department of Energy (DE-CR0000007) and how APPA will use funding to help its members develop and deploy active cyber defense on public power operational technology networks. Discussed federal agency efforts/advisories on ransomware and cybersecurity. Included discussion on SolarWinds. Discussed need for essential utility personnel to get access to COVID-19 vaccine. Discussed public power resiliency efforts. Discussed the impact of COVID-19 on public power utilities and how they were dealing with the pandemic from an operational standpoint; discussed what public power utilities are doing on customer shutoffs during the pandemic; discussed language to establish a federal moratorium on utility shutoffs and prevent the collection of debt included in H.R. 6800, the Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act and H.R. 925, the HEROES Act. Also discussed need to extend mandatory paid sick leave and family medical leave payroll tax credits to governmental entities. Discussed the creation of a forgivable loan program to assist public power utilities negatively impacted by COVID-19. Discussed priorities for inclusion in coronavirus relief legislation - H.R. 133, the Consolidated Appropriations Act, 2021 - forgivable loan program; increased funding for Low Income Home Energy Assistance Program (LIHEAP); rental assistance program, which can also assist renters with utility bills; extension of deadline for using Coronavirus Relief Funds (and additional money for it); and providing public power utilities with comparable incentives for various energy-related tax credits. Also discussed provisions in the bill to provide funding for rural programs and opposition to efforts include language in the bill to prohibit the Federal Reserve from taking steps to ensure municipal market liquidity. Discussed the use of Coronavirus Relief Funds allocated under the CARES Act (Pub. Law 116-136) for utility customer assistance programs. Also discussed use of Paycheck Protection Program funds to pay utility bills (small businesses and nonprofits). Discussed APPA Light Up Navajo Project to provide electric service to Navajo Nation families by using mutual aid from public power utilities to build the infrastructure needed to provide service. Discussed concerns with the inclusion of language (section 5111) in H.R. 4447, the Clean Economy Jobs and Innovation Act in the Energy Act of 2020 (which was then included in H.R. 133 the Consolidated Appropriations, 2021), to direct the Federal Energy Regulatory Commission (FERC) to undertake a rulemaking on interregional transmission planning. Also discussed support for the inclusion of various energy storage provisions (Subtitle C) in the Energy Act of 2020. Also discussed provisions in the Energy Policy Act on grid modernization and electric vehicles. Discussed support for the inclusion of H.R. 3079, the Energy Savings through Public-Private Partnerships Act of 2019, in the Energy Act of 2020. Provided feedback on draft legislation, the Energy Transitions Act, to support communities impacted by the closure of coal facilities. Discussed H.R. 8626, the Energy Resilient Communities Act. Discussed public power microgrid projects. Discussed H.R. 8807, the EV MAP Act. Discussed FERC Notice of Inquiry in RM 20-19 on Potential Risks to Bulk Electric System.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2020 · third_quarter · Q3
Discussed support for H.R. 3967, Municipal Bond Market Support Act (all provisions) and H.R. 2772, Investing in Our Communities Act (all provisions), and their inclusion in coronavirus relief legislation or infrastructure legislation - H.R. 2, the Moving Forward Act. Discussed provisions in S. 4203, the American Infrastructure Bond Act, to restore advance refunding bonds. Discussed allowing governmental entities, including public power utilities, to receive employer payroll tax credit for emergency paid sick leave and paid family leave in PL 116-227, the Families First Coronavirus Relief Act. Discussed H.R. 5523, the Energy Sector Innovation Tax Credit - provisions related to transfer of credit by certain public entities. Discussed provisions relating to the transferability and direct payment of energy tax credits to public power utilities in H.R. 7516, the Clean Energy Innovation and Deployment Act of 2020. Discussed H.R. 7734/S. 4290, the Building Businesses Back Act of 2020 - provisions related making business-related tax credits refundable. Discussed of the definition of taxpayer in H.R. 7330, the Growing Renewable Energy and Efficiency Now (GREEN) Act. Discussed draft proposal to allow monetization of all business tax credits (applicability to public power). Discussed draft legislation to create COVID Recovery Bonds - provisions expanding qualified private activity bond use to any energy facility. Discussed draft legislation to provide that certain retail utility contracts do not constitute private business use of tax-exempt bond proceeds. Discussed need for comparable incentives for various energy-related tax credits for public power utilities.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2020 · second_quarter · Q2
Discussed S. 3688, Energy Infrastructure Protection Act. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed potential legislation granting utilities limited third-party liability protections during a grid security emergency, including support for such legislation. Discussed support for potential Fischer amendment to the Fiscal Year 2021 National Defense Authorization Act (NDAA) to protect facilities with defense critical electric infrastructure (S. 4049). Discussed support for potential Bacon amendment to the Fiscal Year 2021 NDAA to protect facilities with defense critical electric infrastructure (H.R. 6395). Discussed H.R. 7203, GRID Act of 2020. Discussed S. 3728, Critical Infrastructure Employee Protection Act of 2020. Discussed efforts by the electric utility sector to ensure electric service during the COVID-19 pandemic, including efforts undertaken to protect utility workers, obtain testing for key utility personnel, and the need for personal protective equipment for key utility personnel. Also discussed contract tracing for utilities. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Discussed APPA's cooperative agreement with DOE's Infrastructure Security and Energy Restoration Division -Integrating State Energy Assurance and Federal Energy Emergency Response Initiatives with Local Energy Emergency Response (DE-OE0000757). Discussed Cybersecurity Solarium Commission report. Discussed Executive Order 13920, Securing the United States Bulk-Power System. Discussed H.R. 7410, the Hydropower Clean Energy Future Act. Discussed the impact of COVID-19 on public power utilities and how they were dealing with the pandemic from an operational standpoint; discussed what public power utilities are doing on customer shutoffs during the pandemic; discussed language to establish a federal moratoria on utility shutoffs and prevent the collection of debt included in H.R. 6379, the Taking Responsibility for Families and Worker Act, and H.R. 6800, the Health and Economic Recovery Omnibus Emergency Solutions (HEROS) Act Discussed possible need for direct assistance for public power utilities impacted by COVID-19; discussed public priorities for coronavirus relief package following passage of H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act - direct aid, increased funding for the Low Income Home Energy Assistance Program (LIHEAP) and Coronavirus Relief Funds, and completed implementation of the Municipal Liquidity Facility. Discussed priorities for inclusion in coronavirus relief legislation - direct aid, restoration of advance refunding bonds, increasing the small-issuer exception, increased funding for LIHEAP, making emergency supplemental appropriations for the Power Marketing Administrations non-reimbursable; and providing public power utilities with comparable incentives for various energy-related tax credits. H.R. 6800, the Health and Economic Recovery Omnibus Emergency Solutions (HEROS) Act.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2020 · first_quarter · Q1
Discussed support for the restoration of advance refunding bonds and H.R. 2772, the Investing in Our Communities Act. Discussed the need for comparable incentives for public power investments in clean energy and energy storage, including support for S. 1288, the Clean Energy for America Act. Discussed H.R. 2704, the Renewable Energy Transferability Act. Discussed credit transferability in H.R. 5523, the Energy Sector Innovation Act. Discussed support for H.R. 3967, the Municipal Bond Market Support Act. Discussed the sequestration of direct payment bonds and impact on public power utilities. Discussed H.R. 5409, the Incentivizing New and Valuable Energy Storage Technology (INVEST Act), and the need to ensure public power utilities have a comparable energy storage incentive. Discussed H.R. 2096, the Energy Storage Tax Incentive and Deployment Act, and the need to ensure public power utilities have a comparable energy storage incentive. Discussed tax credit refundability in the Growing Renewable Energy and Efficiency Now (GREEN) Act (draft legislation); also discussed provision in GREEN Act related to the direct payment of enhanced deduction for energy efficiency improvements by governmental owners. Discussed Internal Revenue Service private use rules relating to commercial contracts. Discussed provisions in H.R. 6201, the Families First Coronavirus Response Act, that deny payroll tax credits for government employers and impact on public power utilities. Discussed the possible inclusion of energy-related tax credits in H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act.
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2019 · fourth_quarter · Q4
Discussed support for the restoration of advance refunding bonds, H.R. 2772, Investing in Our Communities Act. Discussed possible legislation to reinstate advance refunding bonds. Discussed the need for comparable incentives for public power investments in clean energy and energy storage, including support for S. 1288, the Clean Energy for America Act. Discussed H.R. 2704/S. 3032, the Renewable Energy Transferability Act. Discussed credit transferability in draft version of Energy Sector Innovation Act. Discussed normalization of tax credits. Discussed tax credit refundability in the GREEN Act (draft legislation).
Discussed what public power utilities are doing to reduce their greenhouse gas emissions and support for policies that would reduce emissions, such as energy efficiency, the promotion of hydropower and nuclear power, and the promotion of electric vehicles. Discussed H.R 172, the New Source Review Permitting Improvement Act. Discussed S. 2662, the GAIN Act. Discussed the NESHAP: Coal- and Oil-Fired Electric Utility Steam Generating Units -- reconsideration of supplemental cost finding and residual risk and technology -- EPA-HQ-OAR-2018-0794 Discussed EPA's Affordable Clean Energy Rule (EPA-HQ-OAR-2017-0355: FRL-9995-70-OAR), Air Emissions Transport, Ozone National Ambient Air Quality Standards Implementation.
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2019 · third_quarter · Q3
Discussed APPAs opposition to President Trumps fiscal year 2020 budget proposal to divest the transmission assets of the Power Marketing Administrations (PMAs) and Tennessee Valley Authority and to require the PMAs to charge market-based rates. Discussed funding for cybersecurity for energy delivery systems in fiscal year 2020 Energy and Water Development and Related Agencies Appropriations Act, 2020 (H.R. 2960/S. 2470)
Discussed issues caused by lack of access to federally-guaranteed banks by certain utility customers.
Discussed support for the restoration of advance refunding bonds, H.R. 2772, Investing in Our Communities Act. Discussed support for ending the sequestration of Build America Bonds. Discussed the need for comparable incentives for public power investments in clean energy and energy storage, including support for S. 1288, the Clean Energy for America Act. Discussed the need to increase the small-issuer exemption to $30M and support for H.R. 3967, the Municipal Bond Market Support Act of 2019. Discussed the need to simplify private-use rules for municipal bonds. Discussed the importance of tax-exempt financing for public power infrastructure investments. Provided feedback on H.R. 2704, Renewable Energy Transferability Act. Discussed issues with the output facility private use rules.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2019 · second_quarter · Q2
Discussed support for the restoration of advance refunding bonds, H.R. 2772, Investing in Our Communities Act. Discussed support for ending the sequestration of Build America Bonds. Discussed the need for comparable incentives for public power investments in clean energy and energy storage, including support for S. 1288, the Clean Energy for America Act. Discussed the need to increase the small-issuer exemption to $30M. Discussed the need to simplify private-use rules for municipal bonds. Discussed the importance of tax-exempt financing for public power infrastructure investments. Provided feedback on draft legislation to provide transferability of accumulated energy tax credits. Discussed H.R. 2704, Renewable Energy Transferability Act. Provided feedback on S. 1142, Energy Storage Tax Incentive and Deployment Act of 2019.
Lobbied in support of repealing and replacing of Section 433 of Energy Independence and Security Act -- S. 1245/H.R. 2664. Discussed efforts by public power utilities to promote energy efficiency. Discussed electric vehicles and the development of charging infrastructure by public power utilities. Expressed support for S. 674, the Clean Corridors Act of 2019, and the inclusion of similar language in an infrastructure bill. Lobbied on the need for a permanent repository for spent nuclear waste. Discussed the importance of small modular reactors and the development of new nuclear to help address climate change. Discussed H.R. 3136, Storage and Transportation of Residual and Excess Nuclear Fuel Act of 2019. Provided feedback on draft legislation to provide federally subsidized loans to utilities offering home energy efficiency loans to customers.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2019 · first_quarter · Q1
Discussed support for the restoration of advance refunding bonds, including draft legislation to do so. Discussed support for ending the sequestration of Build America Bonds. Discussed the need for comparable incentives for public power investments in clean energy and energy storage. Discussed the need to increase the small-issuer exemption to $30M. Discussed the need to simplify private-use rules for municipal bonds. Discussed the importance of tax-exempt financing for public power infrastructure investments.
Discussed the need to amend the Stafford Act to allow Federal Emergency Management Agency (FEMA) disaster mitigation funding of projects for which work has already begun. Discussed the need for timely payment of FEMA public assistance grants.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2018 · fourth_quarter · Q4
Provided feedback on and support for H.R. 5240, the Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cybersecurity. Discussed support for legislation to improve the hydropower licensing and relicensing reform process -- H.R. 3043 and provisions in S. 1460. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests, as well as ensuring public power's right to self-supply. Discussed concerns with any proposed attempts by Congress to federalize rate design and how public power is working with its customers to enable distributed energy resources. Discussed implementation of vegetation management legislation now enacted into law, P.L. 115-141, by the U.S. Forest Service and Bureau of Land Management. Provided feedback on S. 1875, the Flexible Grid Interstate Act of 2017. Expressed concerns with the provisions on model standards. Met with FERC on reliability issues and discussed RM 19-10. Met with FERC on generator interconnection policies in Midcontinent ISO.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2018 · third_quarter · Q3
Provided feedback on and support for H.R. 5240, Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Provided feedback on H.R. 5239, Cyber Sense Act of 2018, to establish a volunteer program that identifies and promotes cyber-secure products intended for use in the bulk power system. Discussed the need for enhanced background screening of utility employees and provided feedback on draft legislation. Supported legislation to establish the new Office of Cybersecurity, Energy Security, and Emergency Response (CESER) at the Department of Energy -- H.R. 5174, Energy Emergency Leadership Act. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cybersecurity. Discussed support for legislation to improve the hydropower licensing and relicensing reform process -- H.R. 3043 and provisions in S. 1460. Expressed support for S. 724, a bill to amend the Federal Power Act to modernize authorizations for necessary hydropower approvals. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests, as well as ensuring public power's right to self-supply. Discussed concerns with any proposed attempts by Congress to federalize rate design and how public power is working with its customers to enable distributed energy resources. Discussed concerns with wholesale markets and Federal Energy Regulatory Commission (FERC) intrusion into energy matters that fall within state/local jurisdiction under the Federal Power Act. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Discussed implementation of vegetation management legislation, H.R. 1873, included in H.R. 1625, the Consolidated Appropriations Act, 2018, by the U.S. Forest Service and Bureau of Land Management. Lobbied in support of H.R. 587/S. 186, the FAIR Rates Act. Discussed FERC's ongoing review of form 715 submission requirements.
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2018 · second_quarter · Q2
Discussed the tax-exempt financing of public power infrastructure investments. Lobbied in support of H.R. 5003 to restore advance refunding bonds. Discussed potential ways to change private use restrictions on municipal bonds. Discussed amendment #98 to H.R. 4, the FAA Reauthorization Act, regarding the use of tax-exempt municipal bonds to finance private operation of schools, police stations, courthouses, and other public buildings.
Discussed the need for a statute of limitations on the de-obligation of public assistance grants in disaster relief legislation -- H.R. 4460, the Disaster Recovery Reform Act, and S. 1641, the Post-Disaster Fairness to States Act.
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2018 · first_quarter · Q1
Discussed amendments to the Commodities Exchange relating to regulation of swaps, and swap partners, entered by utility special entities.
Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Discussed FERC's order on grid resiliency -- FERC RM 18-1. Provided feedback on and support for H.R. 5240, Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Provided feedback on H.R. 5239, Cyber Sense Act of 2018, to establish a volunteer program that identifies and promotes cyber-secure product intended for use in the bulk power system. Discussed the need for enhanced background screening of utility employees and provided feedback on draft legislation. Discussed support for legislation to improve the hydropower licensing and relicensing reform -- H.R. 3043 and provisions in S. 1460. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Discussed support for vegetation management legislation, H.R. 1873, and its inclusion in H.R. 1625, the Consolidated Appropriations Act, 2018. Lobbied in support of congressional oversight of the implementation of the Federal Power Act. Discussed FERC policies on distributed energy resources -- FERC RM 16-23. Discussed FERC policies on supply chain cybersecurity -- FERC RM 17-13. Discussed FERC policies on price formation -- FERC RM 17-03; 17-20. Discussed concerns with release of Critical Electric Infrastructure Information -- FERC Form 715. Discussed views on FERC policies on capacity markets. Discussed support for needed reforms to the Public Utility Regulatory Policies Act of 1978 and support for H.R. 4476, the PURPA Modernization Act. Lobbied in support of H.R. 587, the Fair RATES Act, to amend the Federal Power Act to permit a party to seek a rehearing and subsequent judicial review of any rate change by a public utility that takes effect without FERC issuing an order making such change effective. Provided feedback on proposed changes at the Department of Energy to the PMA reporting structure.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2017 · fourth_quarter · Q4
Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Discussed Dept. of Energy's Notice of Proposed Rulemaking on grid resiliency -- FERC RM 18-1. Discussed the importance of the electric utility industry and government partnership to share information and work together on grid security. Provided feedback on proposed legislation permanently authorizing program assisting small- and medium-sized utilities with grid security. Discussed the need for enhanced background screening of utility employees and provided feedback on draft legislation. Discussed need for legislation to improve the hydropower licensing and relicensing reform -- H.R. 3043 and provisions in S. 1460. Discussed views on bills to support closed loop pumped storage and addition of generation at non-powered dams -- H.R. 2880 and H.R. 2872. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Discussed potential for including legislation to improve interstate natural gas pipeline permitting process, such as H.R. 2910 and provisions in S. 1460, in infrastructure legislation. Discussed need for legislation on vegetation management and in support of H.R. 1873. Also support vegetation management language in S. 1460, Energy & Natural Resources Act of 2017. Lobbied in support of congressional oversight of the implementation of the Federal Power Act. Discussed issues related to distributed generation, including rate design and microgrids. Provided feedback on draft bills to promote distributed energy resources. Also provided feedback on S. 1874, Distributed Energy Demonstration Act of 2017, S. 1875, the Flexible Grid Infrastructure Act of 2017, and S. 1876, Reducing the Cost of Energy Storage Act of 2017. Discussed FERC policies on distributed energy resources -- FERC RM 16-23. Discussed FERC policies on accommodating resource policies -- FERC AD 17-11. Discussed FERC policies on Public Utility Regulatory Policies Act -- FERC AD 16-16. Discussed FERC policies on price formation -- FERC RM 17-03; RM 17-20 Discussed needed reforms to the Public Utility Regulatory Policies Act of 1978 and provided feedback on H.R. 4476.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2017 · third_quarter · Q3
Lobbied in support of funding for Cybersecurity for Energy Delivery Systems program at the Department of Energy. Discussed opposition to fiscal year 2018 budget proposal from President that recommends selling the transmission assets of the Power Marketing Administrations. Supported H.Con. Res 71 that opposes the sale of Power Marketing Administration transmission assets proposed in President's FY 2018 budget. Lobbied in support of Power Marketing Administrations and TVA. Also discussed issues specific to the Western Area Power Administration. Expressed support for Presidential Granting of 100 percent reimbursement for category A and B costs for Puerto Rico in the aftermath of Hurricane Maria -- FEMA cost sharing for Notice of Major Disaster for the Commonwealth of PR (FEMA 4339-DR)
Discussed efforts to restore power after Hurricanes Harvey, Irma, and Maria. Discussed the mutual aid process for public power utilities. Expressed support for presidential granting of 100 percent reimbursement for category A and B costs for Puerto Rico in the aftermath of Hurricane Maria -- FEMA cost sharing for Notice of Major Disaster for the Commonwealth of PR (FEMA 4339-DR)
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2017 · second_quarter · Q2
Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Lobbied in support of FAIR Rates Act (H.R. 238). Discussed the importance of the electric utility industry and government partnership to share information and work together on grid security; discussed regulations on grid security; discussed industry efforts on the potential threat of electromagnetic pulse to the electric grid. Discussed need for legislation to improve the hydropower licensing and relicensing reform, including support for H.R. 3043. Discussed need for legislation to improve interstate natural gas pipeline permitting process, including support for H.R. 2910. Discussed need for legislation on vegetation management and in support of H.R. 1873. Lobbied in support of congressional oversight of the implementation of the Federal Power Act. Discussed issues related to distributed generation, including rate design and microgrids. Provided feedback on draft bills to promote distributed energy resources. Discussed the need for enhanced background screening of utility employees. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Discussed H.R. 3050 on state energy security planning and provided feedback on it. Discussed needed reforms to the Public Utility Regulatory Policies Act of 1978. Discussed issues being examined in DOE study on grid reliability, including wholesale markets, renewables, and hydropower.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2017 · first_quarter · Q1
Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Lobbied in support of FAIR Rates Act (H.R. 238). Discussed views on cybersecurity recommendations in the Quadrennial Energy Review 1.2. Lobbied on S. 79 to establish pilot program to examine whether to add manual controls on electric grid. Discussed Electric Power Research Institute report on electromagnetic pulse. Lobbied on S. 529, bill to require the Department of Energy to get approval from state public utility commission and governor before exercising eminent domain to acquire property for S. 1222 transmission lines. Discussed need for legislation to improve the hydropower licensing and relicensing reform. Discussed need for legislation to improve interstate natural gas pipeline permitting process. Discussed need for legislation on vegetation management and in support of H.R. 1873. Lobbied in support of congressional oversight of the implementation of the Federal Power Act. Discussed issues related to distributed generation, including rate design and microgrids. Discussed APPA's comments on Federal Energy Regulatory Commission proceeding on energy storage. Discussed transmission policy. Discussed the importance of the electric utility industry and government partnership to share information and work together on grid security. Discussed bulk power system reliability, including compliance with NERC standards.
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2016 · fourth_quarter · Q4
Lobbied in support of funding for cybersecurity research in H.R. 5055/S.2804
Advocated for H.R. 4441, the Aviation Innovation, Reform, and Reauthorization Act and S. 2658, Federal Aviation Administration Reauthorization re: unmanned aircraft systems.
Supported the continued use of tax-exempt financing for municipal/public power purposes. Lobbied in support of H.R. 5879 regarding the advanced nuclear production tax credit. Lobbied on tax reform efforts.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2016 · third_quarter · Q3
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Lobbied in support of H.R. 5879 regarding the advanced nuclear production tax credit. Lobbied on tax reform efforts. Discussed the need for clarification of the solar residential tax credit (IRC Section 25D).
Advocated for H.R. 4441, the Aviation Innovation, Reform, and Reauthorization Act and S. 2658, Federal Aviation Administration Reauthorization re: unmanned aircraft systems.
Lobbied to require appropriate federal banking agencies to treat certain municipal obligations as level 2A liquid assets and in support of H.R. 2209.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2016 · second_quarter · Q2
Advocated in support of the use of unmanned aerial vehicles (UAV) for utility related operations (Docket FAA-2015-0150). Advocated for H.R. 4441, the Aviation Innovation, Reform, and Reauthorization Act and S. 2658, Federal Aviation Administration Reauthorization re: unmanned aircraft systems.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Lobbied in support of including a fix to the nuclear production tax credit in the tax title of the Federal Aviation Administration (FAA) bill -- H.R. 4441, Aviation Innovation, Reform, and Reauthorization Act/S. 2658 -- FAA Reauthorization. Also lobbied on the need to fix the nuclear production tax credit outside of FAA legislation. Lobbied on potential impact of Internal Revenue Service proposed regulation on the definition of political subdivision (Reg-129067-15.
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2016 · first_quarter · Q1
Advocated in support of the use of unmanned aerial vehicles (UAV) for utility related operations (Docket FAA-2015-0150). Advocated for H.R. 4441, the Aviation Innovation, Reform, and Reauthorization Act and S. 2658, Federal Aviation Administration Reauthorization re: unmanned aircraft systems.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Monitored impacts of sequestration on Build America Bonds (BABs). Advocated on H.R. 2209, to require the federal bonding agencies to treat municipal bonds as high quality liquid assets.
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2015 · fourth_quarter · Q4
Advocated for passage of H.R. 2041/S.1111, the Public Power Risk Management Act - modifying final rule on swap dealers under the Dodd-Frank Wall Street Reform Act regarding special entities and the $25 million ceiling on their hedging transactions. Supported more limited role in Dodd-Frank for non-profit energy end-users. Supported funding for CFTC so that it can properly manage implementation of Dodd-Frank. Supported H.R 2289, the Commodity End-User Relief Act that addresses the treatment of swaps with utility special entities.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Monitored impacts of sequestration on Build America Bonds (BABs).
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2015 · third_quarter · Q3
Advocated for passage of H.R. 2041/S.1111, the Public Power Risk Management Act - modifying final rule on swap dealers under the Dodd-Frank Wall Street Reform Act regarding special entities and the $25 million ceiling on their hedging transactions. Supported more limited role in Dodd-Frank for non-profit energy end-users. Supported funding for CFTC. Supported H.R 2289, the Commodity End-User Relief Act that addresses the treatment of swaps with utility special entities.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Monitored impacts of sequestration on Build America Bonds (BABs).
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2015 · second_quarter · Q2
Opposed any efforts to change the purpose of the PMAs from marketing clean federal hydropower to promoting non-hydro renewables -- still monitoring DOE activities on the PMAs. Opposed to modifying or eliminating tax-exempt financing in any budget proposal, including FY 2016 Administration proposal to cap deductions at 28 percent for higher income earners. Monitored NRC appropriations allocations for the Department of Energy, the federal Power Marketing Administrations, and the Commodity Futures Trading Commission.
Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally. Continued support of revised Senate energy efficiency bill, S. 535, H.R. 906, H.R. 873 and S. 720 Discussed potential legislation to ensure that federal agencies take electric reliability into consideration when developing regulations. Discussed potential comprehensive energy legislation with House and Senate staff. Continued working to ensure small utilities that are defined as small businesses under SBREFA get appropriate consideration under any pending and future EPA and FERC regulations. Worked to ensure that S. 1536, the Senate companion bill to H.R. 527, which modified the Regulatory Flexibility Act included language to fix SBA size standard issue. Supported efforts to delete Section 433 of EISA 2007, which mandates that all federal buildings use no fossil fuel by 2030. While not a federal issue, discussed issues surrounding distributed generation (namely, rooftop solar) with DOE staff and with some offices on Capitol Hill. Discussed the Quadrennial Energy Review (and its focus on distribution, transmission and storage of energy) with DOE and the White House and submitted statements and other materials related to that process. Discussed the need for enhanced liability protection for electric utilities who are subject to a cybersecurity attack. Briefed Senate and House staff on the physical security of the electric system, and opposed additional legislation resulting in greater regulation. Discussed the issue of the availability of spare transformers with DOE and others. Monitored information sharing legislation such as Cybersecurity Information Sharing Act of 2015, S. 754, H.R. 1560, the Protecting Cyber Networks Act, H.R. 1731, the National Cybersecurity Protection Advancement Act of 2015. Expressed support for Pompeo pipeline permitting bill - H.R. 161, which passed the House. Expressed support for H.R. 2358, the Electricity Reliability and Forest Protection Act. Expressed support for H.R. 1073, the Critical Infrastructure Protection Act and S. 1241, the Enhanced Grid Security Act of 2015. Monitored Southeastern Federal Power Administration Rate making procedures. Heavily engaged in pending House energy bill discussion draft on topics that include FERCs role in reviewing rule makings with significant impact on reliability; emergency authority to bulk power systems; hydro relicensing reform; and energy markets issues. In the Senate, also engaged in energy bill process, with specific positions on pending bills included below. S. 1221, the Bulk-Power System Reliability Impact Statement Act Expressed opposition to S. 1233, the PURPA PLUS Act, S. 1264, the Electricity Standard Act, S. 1434, the Energy Storage Promotion and Deployment Act of 2015, S. 1213, the Free Market Energy Bill Act of 2015. Expressed opposition to S. 1063, the American Energy Efficiency Act and S. 1202, the Heat Efficiency through Applied Technology Act. Supported S. 1405, the Severe Fuel Supply Emergency Response Act of 2015.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2015 · first_quarter · Q1
Opposed any efforts to change the purpose of the PMAs from marketing clean federal hydropower to promoting non-hydro renewables -- still monitoring DOE activities on the PMAs. Opposed to modifying or eliminating tax-exempt financing in any budget proposal, including FY 2016 Administration proposal to cap deductions at 28 percent for higher income earners. Monitored appropriations allocations for the Department of Energy, the federal Power Marketing Administrations, and the Commodity Futures Trading Commission.
Monitor issues related to unmanned aerial vehicles (UAV), including use of UAV for utility related operations (Docket FAA-2015-0150). Monitoring FAA re-authorization legislation for related developments.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2014 · fourth_quarter · Q4
Supported legislation, S. 1802, modifying final rule on swap dealers under the Dodd-Frank Wall Street Reform Act regarding special entities and the $25 million ceiling on their hedging transactions (S. 1802 is a companion bill to H.R. 1038, which previously has passed the House) Supported more limited role in Dodd-Frank for non-profit energy end-users. Supported funding for CFTC. Support including H.R. 1038/S. 1802 in CFTC Reauthorization bill. Supported H.R. 4413, the Customeer Protection and End UserRelief Act to streamline Dodd-Frank Wall Street Reform Act rules related to energy end-users. Supported the CFTC in rulemaking (RIN 3038-AE19) allow special entities to hedge by engaging in swap transactions in the same way as do other types of electric utiltiies, and generally supported final rule.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2015 budget proposal, to tax municipal bonds. Supported H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs), including H.R. 789 and H.J.Res. 59.Monitored the Tax Reform Act of 2014 (not introduced) for proposals to tax interest paid on municipal bonds.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2014 · third_quarter · Q3
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2015 budget proposal, to tax municipal bonds. Supported H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs), including H.R. 789 and H.J.Res. 59.Monitored the Tax Reform Act of 2014 (not introduced) for proposals to tax interest paid on municipal bonds.
Opposed any efforts to change the purpose of the PMAs from marketing clean federal hydropower to promoting non-hydro renewables -- still monitoring DOE activities on the PMAs. Opposed to modifying or eliminating tax-exempt financing in any budget proposal, including FY 2015 Administration proposal to cap deductions at 28 percent for higher income earners. Oppose proposal in President's FY 2015 budget to continue to investigate divestiture of TVA.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2014 · second_quarter · Q2
Opposed any efforts to change the purpose of the PMAs from marketing clean federal hydropower to promoting non-hydro renewables -- still monitoring DOE activities on the PMAs. Opposed to modifying or eliminating tax-exempt financing in any budget proposal, including FY 2015 Administration proposal to cap deductions at 28 percent for higher income earners. Oppose proposal in President's FY 2015 budget to continue to investigate divestiture of TVA.
Supported legislation, H.R. 1038, modifying final rule on swap dealers under the Dodd-Frank Wall Street Reform Act regarding special entities and the $25 million ceiling on their hedging transactions. HR1038 has passed the House, and is pending in the Senate -- Senate version introduced as S. 1802. Supported more limited role in Dodd-Frank for non-profit energy end-users. Supported funding for CFTC. Support including H.R. 1038/S. 1802 in CFTC Reauthorization bill. Support CFTC no-action letterallowing special entities to hedge by engaging in swap transactions in the same way as do other types of electric utilities. Support the CFTC in proposing rulemaking to address this issue as well, and generally support proposed rule.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2014 · first_quarter · Q1
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2015 budget proposal, to tax municipal bonds. Support H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs). Supported efforts to reallocate unused Clean Renewable Energy Bonds as part of the tax extenders package considered by SenateFinance Committee.
Opposed to DOE Secretary Chu memo of March 16, 2012, to drastically change the purpose of the PMAs from marketing federal hydropower to promoting non-hydro renewables -- still monitoring DOE activities on the PMAs. Opposed to modifying or eliminating tax-exempt financing in any budget proposal, including FY 2015 Administration proposal to cap deductions at 28 percent for higher income earners. Oppose proposal in President's FY 2015 budget to continue to investigate divestiture of TVA.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2013 · fourth_quarter · Q4
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2014 budget proposal, to tax municipal bonds. Support H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs).
Supported legislation, H.R. 1038, modifying final rule on swap dealers under the Dodd-Frank Wall Street Reform Act regarding special entities and the $25 million ceiling on their hedging transactions -- H.R. 1038 passed the House, and is pending in the Senate -- Senate version introduced in December, S. 1802. Supported more limited role in Dodd-Frank for non-profit energy end-users. Supported funding for CFTC.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2013 · third_quarter · Q3
Supported legislation, H.R. 1038, modifying final rule on swap dealers under the Dodd-Frank Wall Street Reform Act regarding special entities and the $25 million ceiling on their hedging transactions -- H.R. 1038 passed the House, and is pending in the Senate. Supported more limited role in Dodd-Frank for non-profit energy end-users. Supported funding for CFTC as part of debate on H.J.Res. 59.
Opposed to DOE Secretary Chu memo of March 16, 2012, to drastically change the purpose of the PMAs from marketing federal hydropower to promoting non-hydro renewables. Opposed to modifying or eliminating tax-exempt financing in any budget proposal, including FY 2014 Administration proposal to cap deductions at 28 percent for higher income earners. Oppose proposal in President's FY 2014 budget to investigate divestiture of TVA. Oppose S.Con.Res. 8 (see tax section for further explanation).
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2013 · second_quarter · Q2
Supported legislation, H.R. 1038, modifying final rule on swap dealers under the Dodd-Frank Wall Street Reform Act regarding special entities and the $25 million ceiling on their hedging transactions -- H.R. 1038 passed the House, and is pending in the Senate. Supported more limited role in Dodd-Frank for non-profit energy end-users.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2014 budget proposal, to tax municipal bonds. Support H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Supported "Dear Colleague" letter authored by Reps. Ruppersburger & Hultgren expressing support for tax-exempt financing. Monitored impacts of sequestration on Build America Bonds (BABs).
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2013 · first_quarter · Q1
Supported legislation, H.R. 1038, modifying final rule on swap dealers under the Dodd-Frank Wall Street Reform Act regarding special entities and the $25 million ceiling on their transactions. Support more limited role in Dodd-Frank for non-profit energy end-users.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2014 budget proposal, to tax municipal bonds. Support H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs) and related issue of Clean Renewable Energy Bonds.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2012 · fourth_quarter · Q4
Monitoring implementation of legislation, H.R. 4173 (known as the Frank-Dodd Wall Street Reform Act), regulating over-the-counter derivatives markets that our members use to hedge natural gas and electricity prices, to ensure that exemptions for end-users of energy from mandatory clearing are retained, and opposing final rule on swap dealers regarding special entities and the $25 million ceiling on their transactions. Also support more limited role in Dodd-Frank for non-profit end-users.
Support the continued use of tax-exempt financing for municipal/public power purposes, and oppose provisions, like those included in the Administration's FY 2013 budget proposal and S. 727, to tax municipal bonds. Closely monitored development of H.R. 8 (compromise on fiscal cliff), and opposed any efforts to include taxation of municipal bonds in the legislation.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2012 · third_quarter · Q3
Monitoring implementation of legislation, H.R. 4173 (known as the Frank-Dodd Wall Street Reform Act), regulating over-the-counter derivatives markets that our members use to hedge natural gas and electricity prices, to ensure that exemptions for end-users of energy from mandatory clearing are retained, and opposing final rule on swap dealers regarding special entities and the $25 million ceiling on their transactions -- testified to House Agriculture Committee to this effect. Also support more limited role in Dodd-Frank for non-profit end-users.
Support the continued use of tax-exempt financing for municipal/public power purposes, and oppose provisions, like those included in the Administration's FY 2013 budget proposal and S. 727, to tax municipal bonds. Monitor legislation on expiring energy tax provisions such as H.R. 8 and S. 3521.
AMERICAN PUBLIC POWER ASSOCIATION via AMERICAN PUBLIC POWER ASSOCIATION
2012 · second_quarter · Q2
Support for Power Marketing Administration funding and operation and maintenance of hydropower facilities at hydropower facilities at Corps of Engineers and Bureau of Reclamation dams. Opposition to taking the Power Marketing Administrations (PMAs) to market-based as opposed to cost-based rates in any budget proposal. Opposition to DOE Secretary Chu memo of March 16, 2012, to drastically change the purpose of the PMAs from marketing federal hydropower to promoting non-hydro renewables. Opposition to eliminating tax-exempt financing in any budget proposal. Support for the Low-Income Home Energy Assistance Program.
Support the continued use of tax-exempt financing for municipal/public power purposes, and oppose provisions, like those included in the Administration's FY 2013 budget proposal and S. 727, to tax municipal bonds. Oppose H.R. 4348, to rescind Clean Renewable Energy Bond allocations (the comparable incentive to the production tax credit for public power development of renewable resources).
Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed opposition to potential budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 to amend, in whole or in part, 26 USC 6817, elective payment of energy tax credits. Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from the Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025). Discussed opposition to Senate Finance Committee budget reconciliation legislative recommendations pursuant to H.Con.Res. 14 (concurrent resolution on the budget for fiscal year 2025) section 70513(b) (restrictions relating to prohibited foreign entities) provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to H.R. 1, section 70513(b) (restrictions relating to prohibited foreign entities) as passed by the House, provision requiring publicly held debt to be tested for ownership by specified foreign entities. Discussed opposition to section 70512(f), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, and section 70513(a), Termination for Wind and Solar Facilities, ending the production tax credits for projects placed in service after 2027, in Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed support for striking section 70512(f), Elimination of Exception from Phaseout for Elective Payment, from Senate amendment 2360, (the Senate Budget Committee Amendment to H.R. 1). Discussed Elective Pay Blueprint APPA developed for APPA members to guide them on energy tax credits. Discussed support for S. 1481, the LOCAL Infrastructure Act, to reinstate advance refunding bonds. Discussed support for S. 5212, the Enhanced Energy Recovery Act, provisions ensuring tax credits for expanding carbon capture are available via elective payment.
Discussed support for increased funding for the Low Income Home Energy Assistance Program in fiscal year 2026 (no legislation). Discussed support for adequate funding of sections 403 and 406 of the Stafford Act (public assistance grants).
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for S. 1429/H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities. Discussed opposition to the repeal of the Stafford Act (no legislation). Provided feedback to draft legislation, the Fixing Emergency Management for Americans (FEMA) Act, including section 101, to replace existing section 406 cost-based grants with new Stafford Act section 409 estimate-based grants.
Filing targets: Army, Dept of (Corps of Engineers), Defense, Dept of (DOD), Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Discussed support for increased funding for the Low Income Home Energy Assistance Program in fiscal year 2026 (no legislation).
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies and expressed concerns with any legislative efforts to eliminate them. Discussed opposition to potential legislation to amend, in whole or in part, 26 USC 103, tax exemption for municipal bonds. Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed tax credits for hydropower (no legislation). Discussed support for H.R. 1255, the Investing in Our Communities Act, to reinstate the ability to issue tax-exempt advanced refunding bonds.
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities and opposition to any attempts to privatize them in whole or in part. Discussed impacts staff reductions could have on the operations of the federal Power Marketing Administrations. Discussed support for S. 887, the Basin Fund Preservation Act to provide for a memorandum of understanding to address the impacts of a certain record of decision on the Upper Colorado River Basin Fund (all provisions).
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance. Discussed support for its reintroduction in the 119th Congress. Discussed support for H.R. 164, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act, to authorize electric utilities receiving certain emergency assistance for the restoration of power to also carry out cost-effective hazard mitigation activities in combination with the power restoration activities.
Filing targets: Energy, Dept of, HOUSE OF REPRESENTATIVES, SENATE
Discussed support for H.R. 9541, the Promoting Opportunities to Widen Electrical Resilience (POWER) Act, to authorize electrical utilities receiving certain financial assistance under the Robert T. Stafford Disaster Relief and Emergency Assistance Act for the restoration of power to also carry out cost-effective hazard mitigation activities. Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions) to provide financial assistance to a local government or electric cooperative as reimbursement for interest paid on a loan used for emergency or disaster recovery activities later paid for by FEMA assistance.
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed possible funding for the Department of Energy (DOE) to assist manufacturers of distribution transformers in increasing their production (no legislation). Discussed the patchwork of cyber incident reporting requirements and concerns about harmonization, including the Cybersecurity and Infrastructure Security Agencys implementation of the Cyber Incident Reporting for Critical Infrastructure Act (CISA-2022-0010). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey. Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Provided feedback on draft legislation, the Rural Grid Resilience Act, to promote microgrids and grid resilience in rural communities. Discussed the price spike in PJMs 2024 Base Residual Auction and efforts by stakeholders to postpone PJMs 2025 Base Residual Auction. Discussed how the Federal Energy Regulatory Commissions (FERC) regulations impact public power communities despite most public power utilities not being subject to FERC ratemaking regulation. Discussed concerns with transmission affordability and rising transmission costs, and support for policies, such as joint ownership and eliminating unnecessary incentives, that would reduce transmission costs. Discussed concerns regarding the long lead times to interconnect new generation resources, and support for policies that prioritize interconnection for load-serving entities.
Filing targets: Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change. Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed support for H.R. 1837, the Investing in Our Communities Act, to restore advance refunding bonds. Discussed support for S. 1453, the Lifting Our Communities through Advanced Liquidity for Infrastructure Act to restore advance refunding bonds. Discussed possible legislation to address domestic content provisions of elective payment of energy tax credits.
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed H.R. 9083, the SECURE GRID Act, to amend the Energy Policy and Conservation Act to require states to include supporting the physical security, cybersecurity, and resilience of local distribution systems in State energy security plans (all provisions). Provided feedback on draft legislation to promote the deployment of virtual power plants. Provided feedback on draft legislation to help promote the development of renewable energy microgrids in rural communities. Discussed the need for the Department of Energy (DOE) to reduce the administrative burden for grants and other federal funding opportunities through DOE, especially for smaller, less-resourced utilities. Discussed how DOE could improve collaboration with electric utilities. Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed support for S. 2356 from the 117th Congress, the Twenty-First Century Dams Act. Discussed concerns with Form EIA-112, Residential Utility Disconnections Survey. Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet rising electricity demand. Discussed general support for permitting reform to help expedite the construction of energy infrastructure, including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed concerns with sections 401 and 402 in S. 4753, the Energy Permitting Reform Act of 2024, which would expand the Federal Energy Regulatory Commissions jurisdiction over non-jurisdictional entities, and support for amendments 58 and 45 that would exempt Federal Power Act section 201(f) entities from sections 401 and 402 of the legislation. Discussed support for S. 4171, the Making Pipelines Accountable to Consumers and Taxpayers Act. Discussed concerns with H.R. 8032, the Low Income Household Water Assistance Program Establishment Act (all provisions).
Filing targets: Energy, Dept of, HOUSE OF REPRESENTATIVES, SENATE
Discussed support for S. 870, the ADVANCE Act (all provisions) to promote advanced nuclear technologies. Discussed the need for a solution for nuclear waste storage (no bill).
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed DOEs final energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they were improved from proposed standards. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed the Cybersecurity and Infrastructure Security Agency's Notice of Proposed Rulemaking to implement the requirements of the Cyber Incident Reporting for Critical Infrastructure Act of 2022 (Docket Number: CISA-2022-0010) and the need to avoid duplicative reporting requirements. Discussed support for the Charging and Fueling Infrastructure Grant Program under Subtitle D, sec. 11401 of the Infrastructure Investment and Jobs Act (P.L. 115-58). Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed the importance of hydropower as a source of renewable energy for public power utilities. Discussed the importance of hydropower for grid reliability. Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994/H.R. 6653, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed S. 4027/H.R. 7786, the SPEED and Reliability Act of 2024 (section (2)(a)(D)), on the exemption of a facility as in the national interest from review under the National Environmental Policy Act. Discussed concerns with overly stringent Build America/Buy America standards in the Infrastructure Investment and Jobs Act (P.L. 117-58) and the impact those standards have on public power utilities ability to complete grant-funded projects. Discussed the need to increase product and asset availability, price transparency, accountability, and coordination between the natural gas and electric industries to ensure electric reliability (no legislation). Discussed how FERCs Order 1920 (Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17)) was a missed opportunity to deal with cost allocation issues and joint ownership of transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues. Discussed Western markets. Discussed FERCs practice and procedure and generator interconnection issues, including implementation of Order 2023 (Docket No. RM22-14). Discussed power market mitigation for institutional investors (Docket No. AD24-60). Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Discussed S. 4171, the Making Pipelines Accountable to Consumers Act (all provisions). Discussed S. 3820, the Low Income Household Water Assistance Program Establishment Act (sections 2(b) and 2(g). Discussed the White Houses 150 Comeback Communities and public power utilities can better leverage programs and policies included in the Inflation Reduction Act.
Discussed support for funding for the Low Income Home Energy Assistance Program in Fiscal Year 2025 Labor, Health, and Human Services Appropriations Act (not yet drafted legislation). Discussed support for funding through the appropriations for DOE to help address labor and materials shortages for distribution transformers (no bill). Discussed funding being included in the fiscal year 2025 Energy and Water Development Appropriations bill for the Defense Production authorities to help address the distribution transformer supply chain crisis (no bill). Discussed the effects of sequestration under the Budget Control Act and Statutory Pay as You Go Act on public power utilities. Discussed the possible waiver of the sequestration provisions of the Statutory Pay as You Go Act (2 USC 931) as relates to the American Rescue Plan Act (P.L. 117-7). Discussed funding for federal grants to states for the federal Coal Combustions Residuals Permit Program and for language to direct EPA to expedite the review and approval state permit programs.
Discussed general support for the concepts included in draft legislation, the Rural Economic Development Loan Program Collateral Flexibility Act of 2024, and similar language in H.R. 8467, the Farm, Food, and National Security Act of 2024, to give the U.S. Department of Agriculture more flexibility to accept alternative forms of collateral for the Rural Economic Development Loan & Grant Program.
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change. Discussed concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed the likelihood of legislation to amend the tax treatment of municipal bonds. Discussed implementation of 26 USC 45U, the existing nuclear tax credit. Discussed support for direct pay of the nuclear investment tax credit (P.L. 117-169, sec. 13105). Discussed support for adding direct pay to S. 1793/H.R. 5803, the Grid Resiliency Tax Credit Act. Discussed possible changes to the three-year limit on customized commercial contracts under 16 CFR 1.141-7(f)(3) - private use rules for output facilities financed with tax-exempt bonds.
Discussed the Environmental Protection Agency's proposed rules to regulate greenhouse gas emissions from power plants (EPA-HQ-OAR-2023-0072) and the potential impacts to public power utilities, as well as potential impact on affordability and reliability. Discussed concerns with EPAs final rules to regulate greenhouse gas emissions from power plants (EPA-HQ-OAR-2023-0072) and the impact they will have on public power utilities, as well as on affordability and reliability. Discussed the creation of a federal clean energy standard and the need for Congress to provide public power utilities with regulatory certainty. Discussed S.J. Res. 92/H.R. Res. 177, a joint resolution providing for congressional disapproval of EPAs final greenhouse gas regulations for power plants. Discussed EPAs efforts to obtain quality and useful emissions information in its Air Emissions Reporting (EPA-HQ-OAR-2004-0489).
Discussed concerns with third-party efforts to remove the Lower Snake River Dams and the importance of hydropower (no bill). Discussed Columbia River Settlement Agreement and concerns with the potential impact of breaching the Lower Snake River dams on hydropower production, meeting clean energy goals, and grid reliability (no legislation). Discussed Columbia River Treaty negotiations. Discussed support for S. 3581/H.R. 6924, the Hydropower Delivery Rate-reduction Offset (HYDRO) Act. Discussed the issue of the assignment of inequitable costs by the Army Corps of Engineers to the Power Marketing Administrations and their customers. Discussed support for ensuring the Water Resources Development Act (no bill number) protects federal hydropower customers from costs issued by the Army Corps of Engineers for which they receive no benefit. Discussed language to make clear that the Power Marketing Administration Administrators retain full authority on setting rates in draft Water Resources Development Act legislation. Discussed the importance of preserving Power Marketing Administration rate making authority; the application of dam safety costs to state-of-the-art modifications; the Stockton Lake compromise on water supply and hydropower generation; and the study of power deauthorization at Willamette Valley projects in the context of future Water Resource Development Act legislation (no bill). Discussed concerns with sections 121(a) and 121(c) of H.R. 8812, the Water Resources Development Act, regarding the classification of authorized purposes at Corps projects and cost sharing. Also discussed an amendment to the legislation to create a pilot program for Corps projects in AZ, CA, and NV at which the secretary of the Army to declare water supply is an authorized purpose during drought emergencies. Discussed the importance of the federal Power Marketing Administrations that provide federal hydropower to public power utilities. Discussed growing threats to electric utilities from wildfires (no legislation). Discussed S. 4628, the Enhancing Mitigation and Building Effective Resilience Act (all provisions). Discussed H.R. 8160, the Breaking Irresponsible Energy and Commercial Habitats Act (all provisions). Discussed H.R. 8161, the Electric Ratepayer Funding Alternative Act (all provisions). Discussed H.R. 8159, the Abandoning Inconsistent and Rash Environmental Solutions Act (all provisions). Discussed H.R. 8156, the Queries Act (all provisions).
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent DOE from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed support for S. 3627, the Distribution Transformer Efficiency and Supply Chain Reliability Act of 2024 (all provisions). Discussed the need for the FAQS for the Fiscal Years 2022-2023 Funding Cycle for the Department of Energy's Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107) to be clarified regarding eligibility for joint action agencies. Discussed support for DOE's GRIP Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act (all provisions). Discussed S. 1521, the Community & Hydropower Improvement Act (all provisions). Discussed support for S. 2994, the Maintaining and Enhancing Hydroelectricity and River Restoration Act (all provisions). Discussed H.R. 6185, the Guaranteeing Reliable Infrastructure Development (GRID) Act (all provisions). Discussed H.R. 5551/S. 2827, the BIG WIRES Act, to give the Federal Energy Regulatory Commission (FERC) the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed H.R. 6747, the Clean Electricity and Transmission Acceleration Act of 2023 (CETA), to direct FERC to determine the existing electricity transfer capacity between regions and to establish minimum levels of transfer capabilities between each region, and to require each transmission planning region to coordinate with its neighbors to plan for the required interregional transmission (all provisions). Discussed making transmission investment tax credits refundable in CETA, direct pay tax credits. Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand FERCs jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussed the importance of joint ownership opportunities for public power utilities as new transmission projects are being built. Discussed how it could help reduce transmission costs for customers and build community support for transmission projects. Discussed concerns with amendment 8 to H.R. 7023, the Creating Confidence in Clean Water Permitting Act, which would make it more difficult and costly to permit certain electric transmission projects. Discussed electric transmission costs, planning, and joint ownership, including FERCs Notice of Proposed Rulemaking, Building for the Future Through Electric Regional Transmission Planning and Cost Allocation and Generator Interconnection, (Docket RM21-17). Discussed resource adequacy issues across the U.S. Discussed the development of Western markets. Discussed President Bidens Executive Order to promote the safe, secure, and trustworthy development and use of artificial intelligence (AI). Discussed the potential use of AI by electric utilities. Discussed the National Cyber Incident Response Plan. Discussed APPAs involvement in the Navajo Tribal Utility Authoritys (NTUA) Light Up Navajo effort. Also discussed concerns with how the federal permitting process is slowing the ability of NTUA and volunteers to connect additional Navajo Nation homes to the electric grid.
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change. Discussed section 242 of H.R. 2811, the Limit, Save, Grow Act of 2023, that would repeal the taxpayer election of payments, in lieu of credits, for specified energy property and production of electricity from certain renewable resources. Discussion of concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed Treasury guidance relating to utility assistance use of funding under section 5001 of the CARES Act (Coronavirus State and Local Fiscal Relief Funds) as amended by the Consolidated Appropriations Act of 2020. Discussed support for H.R. 1837, the Investing in Our Communities Act to reinstate the ability to issue tax-exempt advance refunding bonds (all provisions). Discussed support for S. 1453, the Lifting Our Communities through Advance Liquidity for Infrastructure Act (LOCAL Infrastructure Act), to reinstate the ability to issue tax-exempt advance refunding bonds (all provisions). Discussed support for potential legislation to increase the small-issuer exception from $10 million to $30 million. Discussed concerns with Proposed Rule: Section 45V Credit for Production of Clean Hydrogen; Section 48(a)(15) Election to Treat Clean Hydrogen Production Facilities as Energy Property (88 FR 8920, REG-117631-23 (additionality requirements for clean power used to generate hydrogen).
Discussed support for funding for the Low Income Home Energy Assistance Program in Fiscal Year 2025 Labor, Health, and Human Services Appropriations Act (not yet drafted legislation). Discussed the effects of sequestration under the Budget Control Act and Statutory Pay as You Go Act on public power utilities. Discussed the possible waiver of the sequestration provisions of the Statutory Pay as You Go Act (2 USC 931) as relates to the American Rescue Plan Act (P.L. 117-7). Discussed the Department of Energys Fiscal Year 2024 Budget Request (Volume 3 IE), which requires most funding through DOEs Office of Indian Energy Policy and Programs to be related to the installation of renewable generation.
Discussed general support for the concepts included in draft legislation, the Rural Economic Development Loan Program Collateral Flexibility Act of 2024 and the Conservation Reserve Program Continuity and Rural Infrastructure Act of 2024, to give the U.S. Department of Agriculture more flexibility to accept alternative forms of collateral for the Rural Economic Development Loan & Grant Program and simplifying federal processes around deploying energy infrastructure.
Filing targets: Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, Treasury, Dept of, White House Office
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change. Discussed section 242 of H.R. 2811, the Limit, Save, Grow Act of 2023, that would repeal the taxpayer election of payments, in lieu of credits, for specified energy property and production of electricity from certain renewable resources. Discussion of concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed the need for timely guidance related to the implementation of Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702 (domestic content requirements for elective payment of energy tax credits).
Discussed support for H.R. 2672, the FEMA Loan Interest Payment Relief Act (all provisions).
Discussed the public power business model. Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at the Department of Energy (DOE) to address the distribution transformer supply chain crisis. Discussed concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. Discussed draft legislation to raise energy efficiency standards for certain types of distribution transformers. Discussed H.R. 4167, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent the Department of Energy from proposing or enacting new energy efficiency standards for distribution transformers for five years. Discussed support for the Department of Energy Grid Resilience and Innovation Partnerships (GRIP) Program (P.L. 117-58, sections 40101, 40103, and 40107). Discussed ways to improve DOE outreach to smaller and rural utilities. Discussed the importance of ensuring federal agencies tasked with awarding competitive loans and grants funded through the Infrastructure Investment and Jobs Act (P.L. 117-58) and Inflation Reduction Act (P.L. 117-169) are providing smaller utilities with the tools they need to apply for such funding, as well as distributing funding to public power utilities. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed H.R. 4045, the Hydropower Clean Energy Future Act, and amendments to the legislation. Discussed H.R. 1389, the Guaranteeing Reliable Infrastructure Development (GRID) Act (all provisions). Discussed draft legislation to ensure electric system reliability. Discussed H.R. 5551, the BIG WIRES Act, to give the Federal Energy Regulatory Commission the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed the North American Electric Reliability Corporation conducting a study on interregional transfer capability as directed under the Fiscal Responsibility Act of 2023 (P.L. 118-5). Discussed the Department of Energy's transmission efforts, including its efforts to improve the siting and permitting of transmission and restarting of its program for national interest corridors. Discussed the need for permitting reform to help expedite the siting and permitting of energy projects to meet emissions reduction goals. Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act to streamline processes but not include transmission-related language that would expand the Federal Energy Regulatory Commissions jurisdiction over cost allocation and potentially saddle public power utilities with additional transmission costs. Discussion of potential legislation on artificial intelligence (no bill). Discussed the potential use of artificial intelligence by electric utilities. Discussed draft legislation, the Grid Reliability and Integrated Data Act, and the potential impact its provisions could have on public power utilities, if enacted (no bill).
Filing targets: Energy, Dept of, HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE, White House Office
Discussed the importance of elective pay refundable energy tax credits included in the Inflation Reduction Act (Pub. Law 117-169) for public power investments in clean energy technologies to address climate change. Discussed section 242 of H.R. 2811, the Limit, Save, Grow Act of 2023, that would repeal the taxpayer election of payments, in lieu of credits, for specified energy property and production of electricity from certain renewable resources. Discussion of concerns with implementation of the domestic content requirements necessary to access elective pay provisions in the Inflation Reduction Act (Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702). Discussed the need for timely guidance related to the implementation of Pub. Law 117-169, sections 13101(g)(2), 13102(l), 13701, and 13702 (domestic content requirements for elective payment of energy tax credits). Discussed S. 1793/H.R. 5803, the Grid Resiliency Tax Credit Act, to provide tax credits for the installation of regionally significant electric power transmission lines. Discussed the need to restore advance refunding bonds and support for H.R. 1837, the Investing in Our Communities Act (all provisions), and S. 1453, supporting Lifting Our Communities through Advance Liquidity for Infrastructure Act or the LOCAL Infrastructure Act (all provisions). Discussed support for legislation in the 117th Congress, H.R. 2634, the Local Infrastructure Financing Tools (LIFT) Act, section 4, to increase the small-issuer exception from $10 million to $30 million.
Discussed how the model of shared responsibility for cybersecurity and resilience, which assigns each critical infrastructure sector a Sector-Risk Management Agency (SRMA) to work closely with on a day-to-day basis (while broadly coordinating with the Department of Homeland Security (DHS)) has and continues to be successful. Expressed support for the Department of Energy (DOE) as the electric sectors SMRA. Discussed how the electric sector has strong mandatory and enforceable cyber and physical security standards, including cyber incident reporting, in place, and why cybersecurity standards and mandates must be risk-based. Discussed physical security and cybersecurity collaboration with the federal government. Discussed the Cyber Incident Reporting Council report released by the Cybersecurity and Infrastructure Security Agency that outlines steps the federal government should take to streamline its incident reporting regulations. Expressed concerns with H.R. 1160, the Critical Electric Infrastructure Cybersecurity Incident Reporting Act (all provisions). Discussed draft legislation to impose cybersecurity baseline standards on distribution utilities (no bill number). Discussed efforts by DOE and other stakeholders on cybersecurity baselines for distribution utilities. Discussed proposed amendments to S. 2226, the Fiscal Year 2024 National Defense Authorization Act - #312 - assessment of existing large power transformers; #249 - study on energy resilience and reliability posture of military departments; #706 - Federal Information and Security Modernization Act of 2023. Discussed S. 914, the Energy Threat Analysis Center Establishment Act of 2023, to establish an energy threat analysis center within the Department of Energy (all provisions). Discussed S. 934, a bill to amend the DOE Organization Act to assign certain functions to the Assistant Secretaries of Energy relating to energy emergencies and energy security, and for other purposes. Discussed potential problems with the implementation of the Rural and Municipal Utility Grant Program at DOE (Sec. 40124(d)(1)(A) of the Infrastructure Investment and Jobs Act) regarding the provision of technical assistance. Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed efforts at DOE to address the distribution transformer supply chain crisis. Discussed concerns with the DOEs proposed energy efficiency standards for distribution transformers (EERE-2019-BT-STD-0018) and how they would worsen the distribution transformer supply chain crisis. Discussed distribution transformer standardization efforts. Discussed efforts to gather further data on distribution transformer shortage. Discussed draft legislation to raise energy efficiency standards for certain types of distribution transformers. Discussed draft legislation, the DOE Appliance and Equipment Standards Reform and Consumer Protection Act. Discussed H.R. 4167/S. 2036, the Protecting Americas Distribution Transformer Supply Chain Act, to prevent the Department of Energy from proposing or enacting new energy efficiency standards for distribution transformers for five years. Expressed concerns with the DOE Grid Resilience and Innovation Partnerships (GRIP) program application requirements, particularly for smaller utilities with limited resources. Provided feedback on how DOE should make the process simpler, more transparent, and provide assistance and support for small and/or rural public power applicants. Discussed public power utilities experiences with applying for Infrastructure Investment and Jobs Act (IIJA) grants, including the GRIP program. Discussion of concerns with domestic content requirements in Infrastructure Investment and Jobs Act (Pub. Law 117-58) and how they make it too difficult for public power utilities to access the grants. Discussed, S. 1521, the Community and Hydropower Improvement Act, and provisions giving tribes mandatory conditioning authority. Discussed the importance of improving the hydropower licensing and relicensing process (no bill). Discussed support for H.R. 4045, the Hydropower Clean Energy Future Act. Discussed support for S. 2994, the Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2023 (all provisions). Discussed draft legislation, the Grid Reliability and Integrated Data Act (all provisions), which could require new and mandatory data collection from utilities, especially smaller utilities. Discussed draft legislation, the BIG WIRES Act, to give the Federal Energy Regulatory Commission the authority to require the expansion of transmission facilities for reliability and establish thresholds for interregional transfer capability (all provisions). Discussed opposition to efforts to reform permitting, siting, and cost allocation processes for electric transmission that significantly expand federal authority or change the beneficiary pays principle (no bill). Discussed support for permitting reform to help expedite the construction of energy infrastructure (no bill), including changes to the National Environmental Policy Act and changes to the Federal Power Act to expedite the construction of transmission while not saddling public power utilities with transmission costs for which they receive no benefit. Discussed support for provisions in H.R. 1577, the BUILDER Act of 2023, to reform the National Environmental Policy Act, that were also included in H.R. 3746, the Fiscal Responsibility Act (Pub. L. No. 118-5).
Discussed support for H.R. 2672/S. 1180, the FEMA Loan Interest Payment Relief Act (all provisions).
Filing targets: Energy, Dept of, HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Office of Management & Budget (OMB), SENATE, Treasury, Dept of, White House Office
Filing targets: Agriculture, Dept of (USDA), Energy, Dept of, Executive Office of the President (EOP), HOUSE OF REPRESENTATIVES, SENATE, Treasury, Dept of
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, Treasury, Dept of
Discussed the importance of direct pay refundable energy tax credits for public power investments in clean energy technologies to address climate change. Discussed support for the provisions in H.R. 5376, the Build Back Better Act, to make refundable, direct pay energy tax credits available to public power utilities - subtitle F, parts 1 (Renewable Electricity and Reducing Carbon Emissions) and 8 (Incentives for Clean Electricity and Transportation). Discussed S. 986, the Carbon Capture, Utilization, and Storage Tax Credit Amendments Act of 2021 (direct pay provision). Discussed the need to restore advance refunding bonds and support for H.R. 2288, the Investing in Our Communities Act, and S. 479, the LOCAL Infrastructure Act. Discussed the need to increase the small-issuer exception. Discussed support for H.R. 2634, the Local Infrastructure Financing Tools Act (provision to increase the small-issuer exception). Discussed S. 1308, the American Bond Infrastructure Act, that would reinstate the ability to issue taxable direct payment bonds similar to Build America Bonds.
Discussed grid security issues, including implementation of the mandatory cyber incident reporting legislation (included in the Consolidated Appropriations Act, 2022 (H.R. 2471)) by the Department of Homeland Securitys Cybersecurity and Infrastructure Security Agency (DHS CISA) and the need to avoid duplicative or conflicting reporting requirements. Discussed the need for DHS CISA to undertake a careful and deliberative implementation process that takes into account existing reporting mandates and to appropriately tailor reporting mandates commensurate with risk to national security. Discussed draft legislation to establish cybersecurity baselines for distribution utilities. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA used the funding to work with its members to improve their cyber hygiene. Discussed APPA's cooperative agreement with the Department of Energy (DE-CR0000007) and how APPA will use funding to help its members develop and deploy active cyber defense on public power operational technology networks. Discussed industry-wide distribution transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed the impact the distribution transformer shortage could have on restoring power after hurricanes. Discussed support for Department of Energy temporarily waiving distribution transformer energy efficiency standards to help spread raw steel materials and increase production volumes. Discussed how the Department of Energy will carry out Defense Production Act-related activities to accelerate domestic production of key technologies, strengthen U.S. power grid reliability, and deploy clean energy. Discussed the strategic transformer reserve provision in section 20301 of H.R. 4521, the America COMPETES Act of 2022. Discussed support for the Infrastructure Investment and Jobs Act (P.L. 117-58) and how it will help public power utilities make clean energy investments. Provided feedback on draft legislation, Leveraging our Water and Energy Data to Reduce (LOWER) Energy Bills Act (no bill number), and draft legislation to establish a National Model Building Performance Standard (no bill number). Provided feedback on draft legislation, the BIDIRECTIONAL Act, to promote vehicle-to-grid technologies. Discussed draft legislation to prohibit the shutoff of electric service during extreme weather events. Discussed the need for the reliable delivery of natural gas for electricity generation. Discussed H.R. 5749, the Gas Consumer Emergency Market Protection Act, and H.R. 6084, the Energy Product Reliability Act. Discussed transmission issues, including inter-regional transmission planning, cost allocation, siting, and permitting. Also discussed rising transmission costs for public power utilities and the need for joint ownership of transmission by public power utilities. In addition, discussed issues with the interconnection queue in certain regional transmission markets. Provided feedback on draft legislation, the BIG WIRES Act, to give the Federal Energy Regulatory Commission the authority to require the expansion of transmission facilities for reliability, among other things. Discussed the need for permitting reform to enable the siting and construction of energy infrastructure. Provided feedback on the transmission provisions in the Energy Independence and Security Act of 2022 (no bill number). Discussed the Federal Energy Regulatory Commissions (FERC) proposed directive to the North American Electric Reliability Corporation (NERC) to address concerns pertaining to transmission system planning for extreme heat or cold weather events that impact the reliable operation of the Bulk-Power System (RM-22-10). Discussed the cost management proposal in FERCs Notice of Proposed Rulemaking on Transmission Planning (RM-21-17). Discussed FERC regulation of public power utilities.
Discussed support for language to fiscal year 2023 appropriations (no bill number) to clarify that Congress did not intend for funding provided to the Army Corps of Engineers in the Infrastructure Investment and Jobs Act and Disaster Relief Supplemental Appropriations Act, 2022 to be paid back by federal hydropower customers. Discussed funding for the Department of Energy for use to carry out Defense Production Act-related activities to accelerate domestic production of key technologies, strengthen U.S. power grid reliability, and deploy clean energy. (Title III) in H.R. 8255/S. 4660, Energy and Water Development and Related Agencies Appropriations Act, 2023. Discussed support for supplemental funding for the Low Income Home Energy Assistance Program in H.R. 6833, the Continuing Appropriations and Ukraine Supplemental Appropriations Act, 2023.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Discussed support the inclusion of provisions to provide direct pay refundable energy tax credits to public power utilities in S. 2118, the Clean Energy for America Act. Discussed support for the inclusion of provisions in H.R. 5376, the Build Back Better Act, to make refundable, direct pay energy tax credits available to public power utilities - subtitle F, parts 1 and 8. Discussed support for S. 2306, the Maintaining and Enhancing Hydroelectricity and River Restoration Act of 2021, discussed support for the inclusion of a 30 percent tax credit to support upgrades at existing hydroelectric dams for qualified dam safety, environmental, and grid resilience improvements in the Senate version of the Build Back Better Act; (no bill number). Discussed support for H.R. 2288, the Investing in Our Communities Act, to restore advance refunding bonds. Discussed support for legislation to increase the small-issuer exception - H.R. 2634, the Local Infrastructure Financing Tools Act. Discussed concerns with the sequestration of direct payment bonds, including Build America Bonds and New Clean Renewable Energy Bonds. Discussed potential legislation to waive the deficit effects of the American Rescue Plan Act (Pub. Law 117-2) for purposes of the Pay as You Go Act (Pub. Law 111-39) to avoid sequestration of Build America Bonds payments.
Discussed bills to require cyber incident reporting by critical infrastructure sectors to the federal government - S. 2875, the Cyber Incident Reporting Act of 2021 (all provisions); H.R. 5440, the Cyber Incident Reporting for Critical Infrastructure Act of 2021 (all provisions); S. 2407, the Cyber Incident Notification Act of 2021 (all provisions); S. 3600, the Strengthening American Cybersecurity Act (all provisions); and H.R. 2471, the Consolidated Appropriations Act of 2022 (cyber incident reporting provision in Division Y - this was eventually signed into law). Discussed implementation of cyber incident reporting legislation included in the Consolidated Appropriations Act, 2022 (H.R. 2471). Discussed the importance of protecting the role of the Department of Energy (DOE) as the energy sectors risk management agency. Discussed comments APPA filed with DOE to its Request for Information, entitled Energy Sector Supply Chain Review. Discussed industry-wide transformer shortage and equipment supply chain challenges. Also discussed the need for more domestic production of electrical equipment. Discussed the strategic transformer reserve provision in section 20301 of H.R. 4521, the America COMPETES Act of 2022. Discussed several DOE grants APPA has received to support the cybersecurity posture of public power utilities, as well as to deploy cyber and cyber-physical solutions for public power utilities. Discussed public power utilities' efforts to transition to cleaner energy technologies, efforts to advance electrification, and modernize the grid. Discussed challenges public power utilities face in these efforts; and how programs in the Infrastructure Investment and Jobs Act could be helpful to public power utilities in their efforts. Discussed DOE's Notice of Intent (NOI) on Building a Better Grid Initiative To Upgrade and Expand the Nation's Electric Transmission Grid To Support Resilience, Reliability, and Decarbonization, which seeks to implement provisions from the Infrastructure Investment and Jobs Act, including the transmission needs study, the Transmission Facilitation Program, transmission corridor authority, and resiliency programs. Discussed implementation of the provisions in the Infrastructure Investment and Jobs Act by DOE on grid modernization, cybersecurity, resilience, and electric vehicles (EVs) (in coordination with the Department of Transportation (DOT)). Discussed implementation by DOE of provisions in H.R. 3684, the Infrastructure Investment and Jobs Act, that would be helpful to public power utilities, including provisions on cybersecurity, grid modernization, resilience, and the deployment of EV charging infrastructure (in conjunction with the DOT) (sections 11401, 40101, 40107, 40121, 40123, and 40124) and public powers transition to cleaner energy resources. Discussed the implementation of provisions in H.R. 3684, the Infrastructure Investment and Jobs Act, to provide grants to public power utilities and other entities to deploy charging infrastructure along designated corridors on the National Highway System. Discussed what public power is doing to enable EVs, including support for federal incentives included in H.R. 3684, the Infrastructure Investment and Jobs Act, and the ability of public power utilities to have access to those incentives. Discussed the role of public power utilities in helping deploy EV charging infrastructure. Also discussed public power EV rebate programs and EV fleet programs. In addition, discussed the need for flexibility and local decision making in the deployment of charging infrastructure and the importance of electric utility involvement in such deployment to ensure reliability. Discussed role of electric utilities in National Electric Vehicle Infrastructure (NEVI) program, including the need for engagement with utilities on state plans and siting decisions and the potential for federal funding to cover EV "make-ready" costs that would otherwise be borne by utility or site host. Discussed support for the inclusion of language in the Infrastructure Investment and Jobs Act to increase the Bonneville Power Administrations borrowing authority. Discussed support for the RD&D provisions in the Infrastructure Investment and Jobs Act to promote hydrogen, carbon capture and storage, and energy storage technologies. Discussed support for clean energy and research and development provisions in the Energy Act of 2020 (Division Z of H.R. 133, the Consolidated Appropriations Act, 2021). Discussed the importance of hydropower as an electricity resource for public power utilities and support for modernizing the hydropower licensing and relicensing process, including support for H.R. 1588, the Hydropower Clean Energy Future Act. Discussed the need for the reliable delivery of natural gas for electricity generation. Provided feedback on H.R. 5749, the Gas Consumer Emergency Market Protection Act (all provisions). Discussed natural gas futures price spike and impact to some public power utilities. Provided feedback on potential a Federal Energy Regulatory Commission (FERC)-related bill, on regional transmission organizations, joint ownership of transmission, the need for regulatory reform on federal transmission siting, and the streamlining of hydropower relicensing process. Discussed transmission issues, including inter-regional transmission planning, cost allocation, siting, and permitting. Also discussed rising transmission costs for public power utilities and the need for joint ownership of transmission by public power utilities. In addition, discussed issues with the interconnection queue in certain regional transmission markets. Discussed support for siting and permitting reform to enable the construction of clean energy infrastructure, including transmission.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE, Transportation, Dept of (DOT)
Discussed support for H.R. 1917, the Hazard Eligibility and Local Projects Act, and H.R. 2669/S. 2212, the FEMA Loan Interest Payment Relief Act. Discussed H.R. 5689, the Resilient AMERICA Act (provisions regarding hazard mitigation). Discussed disaster response and recovery programs; mutual coordination programs; and emerging issues related to disaster recovery for public power utilities.
Discussed the potential impact of vaccine mandates on the Power Marketing Administrations and public power utilities (Executive Order #14043, Requiring Coronavirus Disease 2019 Vaccination for Federal Employees, and OSHA Emergency Temporary Standard 2021-007). Provided feedback on S. 2407, the Cyber Incident Notification Act of 2021. Provided feedback on S. 2875, the Cyber Incident Reporting Act of 2021, and H.R. 5440, the Cyber Incident Reporting for Critical Infrastructure Act of 2021 (all provisions). Discussed cybersecurity-related provisions in S. 1605, the Fiscal Year 2022 National Defense Authorization Act (i.e., on cyber incident reporting language and language on defense critical electric infrastructure). Discussed the importance of grid resilience and the role of the Electric Subsector Coordinating Council. Discussed implementation of provisions in H.R. 3684, the Infrastructure Investment and Jobs Act, that would be helpful to public power utilities, including provisions on cybersecurity, the deployment of EV charging infrastructure, and their transition to cleaner energy resources (sections 11401, 40101, 40107, 40121). Discussed barriers to public power utilities deploying renewables and policies that would be helpful for removing such barriers, such as providing public power utilities with various energy-related tax credits and money for research, development, and demonstration of emerging clean technologies. Discussed how public power utilities are enabling community solar projects. Discussed support for the inclusion of language in H.R. 3684, the Infrastructure Investment and Jobs Act, to move the Southwestern Power Administration to a self-financing model. Discussed the role of public power utilities in helping deploy electric vehicle (EV) charging infrastructure. Also discussed public power EV rebate programs and EV fleet programs. In addition, discussed the need for flexibility and local decision making in the deployment of charging infrastructure and the importance of electric utility involvement in such deployment to ensure reliability. Discussed the implementation of provisions in H.R. 3684, the Infrastructure Investment and Jobs Act, to provide grants to public power utilities and other entities to deploy charging infrastructure along designated corridors on the National Highway System. Discussed transmission issues, including inter-regional transmission planning, cost allocation, siting, and permitting. Also discussed rising transmission costs for public power utilities and the need for joint ownership of transmission by public power utilities. In addition, discussed issues with the interconnection queue in certain regional transmission markets. Discussed draft legislation to address natural gas prices, the Gas Consumer Emergency Protection Act. Discussed recommendations in the Federal Energy Regulatory Commission-North American Electric Reliability Corporation report entitled, The February 2021 Cold Weather Outages in Texas and the South Central United States.
Filing targets: Council on Environmental Quality (CEQ), Energy, Dept of, Environmental Protection Agency (EPA), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Natl Economic Council (NEC), Office of Management & Budget (OMB), SENATE, Transportation, Dept of (DOT), Treasury, Dept of, White House Office
Discussed cybersecurity-related amendments to S. 2377, the Energy Infrastructure Act, and potential impact to public power. Discussed support for H.R. 2931, the Enhancing Grid Security Through Public-Private Partnerships Act. Discussed S. 2483, the Improving Cybersecurity of Small Organizations Act. Discussed the NCS 100-Day Industrial Control Systems (ICS) Cybersecurity Initiative. Discussed concerns with the mandatory reporting mandates in S. 2407, the Cyber Incident Notification Act of 2021. Provided feedback on S. 2875, the Cyber Incident Reporting Act of 2021, and H.R. 5449, the Cyber Incident Reporting for Critical Infrastructure Act of 2021 (all provisions). Discussed the cybersecurity provisions in H.R. 3684, the Infrastructure Investments and Jobs Act, including support for information disclosure protection provisions and additional funding to the Department of Energy (DOE) for grants to public power utilities for cyber programs (Senate version). Provided feedback on provisions of interest to public power utilities in the Energy Infrastructure Act (discussion draft), which eventually became S. 2377 (electric vehicles (EVs), clean energy technologies, grid resilience, hydropower, and wildfire mitigation). Expressed opposition to the inclusion of the text of H.R. 4027, the Efficient Grid Interconnection Act, as an amendment to S. 2377, the Energy Infrastructure Act. Also opposed an amendment to the legislation that would make changes to the Federal Power Act to change the interstate transmission siting process. Discussed amendment by Senator Mark Kelly on the purchase of energy generated by Indian tribes or tribal energy development organizations by federal Power Marketing Administrations to S. 2377, the Energy Infrastructure Act. Discussed support for provisions in H.R. 3684, the Infrastructure Investment and Jobs Act, that would be helpful to public power utilities, including provisions on cybersecurity, the deployment of EV charging infrastructure, and their transition to cleaner energy resources (sections 11401, 40101, 40107, 40121). Discussed language in H.R. 3684, the Infrastructure Investment and Jobs Act, to allow the use of private activity bonds to finance carbon capture facilities. Discussed support for an amendment to H.R. 3684, the Infrastructure Investment and Jobs Act, to move the Southwestern Power Administration to a self-financing model. Discussed the H.R. 4326, the EV Map Act and support for the legislation. Discussed the role of public power utilities in helping deploy EV charging infrastructure. Also discussed public power EV rebate programs and EV fleet programs. Discussed support for language in infrastructure legislation to provide grants to public power utilities and other entities to deploy charging infrastructure along designated corridors on the National Highway System. Discussed opposition to amendments offered, but not made in order, to H.R. 3684, the INVEST Act, that would limit electric utilities role in the deployment of EV charging infrastructure (House version of legislation). Discussed transmission issues, including interregional transmission planning, cost allocation, siting, and permitting. Also discussed rising transmission costs for public power utilities and the need for joint ownership of transmission by public power utilities. Provided feedback on transmission provisions in H.R. 1512, the CLEAN Future Act. Discussed hydropower-related amendments to S. 2377, the Energy Infrastructure Act, to ensure that dam removal provisions do not apply to federal hydropower dams.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE, Treasury, Dept of, White House Office
Discussed potential cybersecurity legislation to require incident reporting, systemically important infrastructure, and other proposals from the Cyberspace Solarium Commission. Provided feedback on draft legislation (no bill number). Discussed concerns with potential efforts to impose additional mandatory reporting requirements on electric utilities regarding grid security. Discussed support for H.R. 2931, the Enhancing Grid Security Through Public-Private Partnerships Act. Discussed draft legislation regarding ransomware. Discussed how the Department of Energy (DOE) is approaching energy sector supply chain security, including DOEs Request for Information (RFI) to replace the Executive Order on the Bulk Power System (EO 13920). Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed existing, mandatory and enforceable reporting standards for electric utilities. Discussed the NCS 100-Day Industrial Control Systems (ICS) Cybersecurity Initiative. Discussed concerns with the draft Warner/Rubio cyber incident reporting legislation, including opposition to mandatory reporting mandates. Discussed concerns with provisions to direct the Federal Energy Regulatory Commission (FERC) to issue a rulemaking on rate incentives for advanced cybersecurity technology. Discussed support for H.R. 2928/S. 2199, the Cybersense Act of 2021. Discussed support for H.R. 3119, the Energy Emergency Leadership Act. Discussed threats from ransomware and potential solutions (no bill number). Discussed H.R. 1833, the Department of Homeland Security ICS Enhancement Act. Discussed the cybersecurity provisions in the Energy Infrastructure Act (no bill number), including support for information disclosure protection provisions and additional funding to DOE for grants to public power utilities for cyber programs. Discussed APPA response to DOEs RFI on Energy Sector Supply Chain Security. Discussed support for an amendment offered to S. 1260, the U.S. Competition and Innovation Act, to clarify that the Department of Homeland Security (DHS) must coordinate with DOE during cyber events affecting the electric sector. Also discussed potential amendments to the bill on electric sector related issues. Discussed support for amending S. 1316, the Cyber Response and Recovery Act, to ensure DHS coordinates with DOE during cyber events affecting the electric sector. Discussed support for DOE funding public power resiliency grants (no bill number). Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA used the funding to work with its members to improve their cyber hygiene. Discussed APPA's cooperative agreement with the Department of Energy (DE-CR0000007) and how APPA will use funding to help its members develop and deploy active cyber defense on public power operational technology networks. Discussed derivatives of DOEs Cybersecurity Capability Maturity Model (C2M2). Discussed need for Congress to look into FEMAs denial of public assistance for control room sequestration during the COVID-19 pandemic. Discussed APPA Light Up Navajo Project to provide electric service to Navajo Nation families by using mutual aid from public power utilities to build the infrastructure needed to provide service. Discussed community solar issues and possible legislation to spur community solar. Also discussed concerns with creating a must-consider requirement section 111 of the Public Utility Regulatory Policies Act (PURPA) for community solar. Discussed details on the National Community Solar Partnership and provided examples of public power utilities with community solar projects. Discussed potential legislation promote demand response programs by electric utilities. Discussed work being done by public power utilities on green hydrogen. Also discussed work APPA did with Berkeley Lawrence National Laboratory on community solar. Discussed potential energy-related provisions that could be included in an infrastructure package, including ones on transmission and promoting clean energy technologies. Discussed the role of public power utilities in helping deploy electric vehicle (EV) charging infrastructure. Also discussed public power EV rebate programs and EV fleet programs. Discussed support for language in infrastructure legislation to provide grants to public power utilities and other entities to deploy charging infrastructure along designated corridors on the National Highway System. Provided feedback on EV provisions in H.R. 1512, the CLEAN Future Act. Expressed opposition to the potential inclusion of language in H.R. 3684, the INVEST Act, that would limit electric utilities role in the deployment of EV charging infrastructure. Discussed transmission issues, including interregional transmission planning, cost allocation, siting, and permitting. Also discussed the need for joint ownership of transmission by public power utilities. Provided feedback on H.R. 2678, the Interregional Transmission Planning Improvement Act. Noted concerns about costs, cost allocation, and firm transmission rights. Discussed concerns with H.R. 616, Emergency Water Is a Human Rights Act. Discussed calls by former FERC Commissioners to have FERC mandate all electric utilities participate in regional transmission organizations. Discussed initiative on transmission by the National Association of Regulatory Utility Commissioners. Discussed revisions to National Electric Reliability Corporation (NERC) reliability standard BAL-003. Also discussed low impact assets under NERC standard CIP-002. Discussed provisions in H.R. 1848, the LIFT America Act, on EVs, transmission, and distributed energy resources. Discussed potential hydropower-related provisions in draft infrastructure legislation.
Discussed support for H.R. 2669, the FEMA Loan Interest Payment Relief Act. Discussed support for the Federal Emergency Management Agency (FEMA) covering the cost of emergency protective measures taken during the COVID-19 pandemic (no legislation). Discussed support for H.R. 1917, the Hazard Eligibility and Local Projects Act.
Discussed the need for appropriations to the Environmental Protection Agency for federal and state permitting programs for coal combustion residuals. Discussed President Bidens fiscal year 2022 Budget Submission to Congress.
Filing targets: Agriculture, Dept of (USDA), Council on Environmental Quality (CEQ), Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, White House Office
Discussed the need for appropriations to the Environmental Protection Agency for federal and state permitting programs for coal combustion residuals. Discussed fiscal year 2022 funding for the Low Income Home Energy Assistance Program (no bill yet).
Discussed draft version of the Energy Sector Innovation Tax Credit - provisions related to the transfer of credits by certain public entities. Discussed the availability of energy-related production and investment tax credits to public power utilities under section 45 and 48 26 of the U.S. Code. Discussed draft version of the Clean Energy for America Act - provisions relating to direct payment bonds. Discussed draft legislation to provide a tax credit for energy storage and the need for it to be available to public power utilities. Discussed direct pay provisions for tribes and the definition of governmental entities as taxpayers in the draft and introduced versions of H.R. 848, the Growing Renewable Energy and Efficiency Now (GREEN) Act. Discussed the need for comparable incentives for various energy-related tax credits for public power utilities. Discussed the need to restore advance refunding bonds (referenced support for legislation from the 116th Congress, H.R. 2722, the Investing in Our Communities Act, and S. 479, the LOCAL Infrastructure Act). Discussed the need to increase the small-issuer exception. Provided feedback on draft legislation, the Microgrid Resilience Tax Credit Act. Discussed provisions to extend the tax credit to public power utilities. Discussed the provision in draft legislation, the Promoting Sustainable Energy Projects for Tribal Communities Act, related to tax return needed to be filed to claim credits. Discussed the need to make the energy storage tax credit available to public power utilities in the draft version of the Incentivizing New and Valuable Energy Storage Technology Act. Discussed support for the Driving America Forward Act (S. 1094 from the 116th Congress).
Discussed draft version of the FEMA Loan Interest Payment Relief Act - all provisions.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Natl Security Council (NSC), SENATE, White House Office
Discussed support for H.R. 8701, the FEMA Loan Interest Payment Relief Act.
Discussed allowing governmental entities, including public power utilities, to receive employer payroll tax credit for emergency paid sick leave and paid family leave in PL 116-227, the Families First Coronavirus Relief Act. Discussed H.R. 5523, the Energy Sector Innovation Tax Credit - provisions related to transfer of credit by certain public entities. Provided feedback on provisions regarding the release of annual Energy Information Administration data and impact on what tier of credit a project would qualify for. Discussed H.R. 7734/S. 4290, the Building Businesses Back Act of 2020 - provisions related making business-related tax credits refundable. Discussed provisions making energy tax credits refundable in H.R. 7330, the Growing Renewable Energy and Efficiency Now (GREEN) Act, and H.R. 2, the Moving Forward Act. Discussed extending expiring tax credits in H.R. 133, the Consolidated Appropriations Act, 2021. Discussed draft legislation to provide that certain retail utility contracts do not constitute private business use of tax-exempt bond proceeds. Discussed need for comparable incentives for various energy-related tax credits for public power utilities.
Discussed support for additional funding for the Low Income Home Energy Assistance Program in H.R. 133, the Consolidated Appropriations Act, 2021.
Filing targets: Energy, Dept of, Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), SENATE
Expressed support for making emergency supplemental funds appropriated to the Power Marketing Administrations, Army Corps of Engineers, and Bureau of Reclamation non-reimbursable in coronavirus relief legislation, including H.R. 925, the HEROS Act. Discussed support for additional funding for the Low Income Home Energy Assistance Program in H.R. 925, the HEROES Act. Discussed concerns regarding the August 24, 2020, Memorandum of Understanding between the Department of Energy, U.S. Bureau of Reclamation, and Army Corps of Engineers on Federal Hydropower. Discussed committee report language for H.R. 7613, the Energy and Water and Related Agencies Appropriations Act, 2021, to require an Energy Information Administration report on utility reporting of emissions related to retail customer usage. Discussed Pub. Law 116-94, the Energy and Water and Related Agencies Appropriations Act, 2020 - joint explanatory statement of managers on funding for cybersecurity grant programs.
Provided feedback on the H.R. 7516, the Clean Energy Innovation and Deployment Act, all provisions. Discussed draft CLEAN Future Act. Discussed climate policy. Discussed EPA docket EPA-HQ-OW-2009-0819 on Effluent Limitations Guidelines and Standards for the Steam Electric Power Generating Point Source Category.
Discussed S. 3688, Energy Infrastructure Protection Ac of 2020. Discussed S. 4795, the Cyber Sense Act. Expressed support for House consideration of H.R. 359, the Enhancing Grid Security through Public-Private Partnerships Act; H.R. 360, the Cyber Sense Act of 2020; and H.R. 362, the Energy Emergency Leadership Act. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed support for potential Crow amendment to the Fiscal Year 2021 National Defense Authorization Act (NDAA) on defense critical electric infrastructure (H.R. 6395). Discussed opposition to the Richmond amendment to the House NDAA bill that would require mandatory cyber incident reporting. Discussed support for Bacon amendment to the House NDAA bill to protect facilities with defense critical electric infrastructure. Discussed King amendment on cyber exercise to the Senate National Defense Authorization Act for Fiscal Year 2021 (S. 4049). Discussed efforts by the electric utility sector to ensure electric service during the COVID-19 pandemic, including efforts undertaken to protect utility workers, obtain testing for key utility personnel, and the need for personal protective equipment for key utility personnel. Also discussed contact tracing for utilities. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Discussed funding through the Department of Energys Office of Cybersecurity, Energy Security, and Emergency Response to develop and deploy cyber and cyber-physical solutions for distribution and municipal utilities. Discussed the impact of COVID-19 on public power utilities and how they were dealing with the pandemic from an operational standpoint; discussed what public power utilities are doing on customer shutoffs during the pandemic; discussed language to establish a federal moratoria on utility shutoffs and prevent the collection of debt included in H.R. 6800, the Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act. Discussed the creation of a forgivable loan program to assist public power utilities negatively impacted by COVID-19. Discussed priorities for inclusion in coronavirus relief legislation - forgivable loan program, restoration of advance refunding bonds, increasing the small-issuer exception, increased funding for Low Income Home Energy Assistance Program (LIHEAP), making emergency supplemental appropriations for the Power Marketing Administrations non-reimbursable; and providing public power utilities with comparable incentives for various energy-related tax credits. H.R. 6800, the Health and Economic Recovery Omnibus Emergency Solutions (HEROES) Act; H.R. 925, the HEROES Act; and the Health, Economic Assistance, Liability Protection, and Schools (HEALS) Act. Discussed the use of Coronavirus Relief Funds allocated under the CARES Act (Pub. Law 116-136) for utility customer assistance programs. Discussed support for increased funding for Coronavirus Relief Funds and more flexibility in the use of such funds. Discussed S. 4362, the Emergency Water and Energy Is a Human Right Act. Discussed the public power business model. Discussed draft legislation - the Expanding Access to Sustainable Energy Act. Discussed support for S. 2657, the American Energy Innovation Act. Discussed impact of Hurricane Laura on public power utility in Louisiana. Discussed H.R. 3079, the Energy Savings through Public-Private Partnerships Act of 2019. Discussed views on Federal Energy Regulatory Commission (FERC) on Cybersecurity Incentives. Discussed cybersecurity issues at public power communities that also provide water service. Discussed the following FERC dockets/matters - Transmission Incentives Notice of Proposed Rulemaking (PL 19-3-00) (RM20-10); Resource Adequacy and Capacity Markets (no docket); Performance Metrics (AD19-16); and Notice of Inquiry in RM 20-12 relating to coordinated cyber-attacks.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Interior, Dept of (DOI), Office of Management & Budget (OMB), SENATE
Discussed APPA's opposition to President Trump's fiscal year 2021 budget proposal to divest the transmission assets of the Power Marketing Administrations (PMAs) and Tennessee Valley Authority and to require the PMAs to charge market-based rates. Expressed support for making emergency supplemental funds appropriated to the Power Marketing Administrations, Army Corps of Engineers, and Bureau of Reclamation non-reimbursable in coronavirus relief legislation, including H.R. 6800, the HEROS Act. Supported additional funding for the Low Income Home Energy Assistance Program in H.R. 6800, the HEROS Act. Lobbied for increased funding to the Environmental Protection Agency for federal and state permitting programs for coal combustion residuals in fiscal year 2021.
Discussed support for H.R. 3967, Municipal Bond Market Support Act (all provisions) and H.R. 2772, Investing in Our Communities Act (all provisions), and their inclusion in coronavirus relief legislation or infrastructure legislation - H.R. 2, the Moving Forward Act. Discussed the impact of public power utilities not receiving employer payroll tax credit for emergency paid sick leave and paid family leave in PL 116-227, the Families First Coronavirus Relief Act. Discussed draft refundable tax credit for arrearages incurred by utilities that suspended service disconnects during the COVID-19 national emergency. Discussed draft of Rewarding American Workers Act - provisions related to payroll tax credits for employers. Discussed H.R. 5523, Energy Sector Innovation Tax Credit - technical correction to ensure applicability to public power utilities. Discussed H.R. 7058, Rewarding American Workers Act - provisions related to payroll tax credits for employers. Discussed provisions relating to the transferability and direct payment of energy tax credits to public power utilities in the Clean Energy Innovation and Deployment Act of 2020 (draft legislation). Discussed draft of COVID private activity bond legislation - provisions relating to use of private activity bond for energy projects and acquisition of existing facilities. Discussed draft of Growing Renewable Energy and Efficiency Now (GREEN) Act - provision related to direct payment of energy tax credits to governmental owners. Also discussed once introduced as H.R. 7330. Discussed draft proposal to allow monetization of all business tax credits (applicability to public power). Discussed H.R. 2, Moving Forward Act - provisions relating to sequestration of infrastructure bonds. Discussed impact of PL 112-25, Budget Control Act of 2011 - provisions relating to sequestration of direct payment of Build America Bond credits.
Provided feedback on the Clean Energy Innovation and Deployment Act (draft climate change legislation), including provisions relating to the transferability and direct payment of energy tax credits to public power utilities.
Filing targets: Energy, Dept of, Federal Communications Commission (FCC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE
Discussed potential ways to address third-party liability concerns during a national security emergency and during a national public health emergency. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Discussed APPA's cooperative agreement with DOE's Infrastructure Security and Energy Restoration Division -Integrating State Energy Assurance and Federal Energy Emergency Response Initiatives with Local Energy Emergency Response (DE-OE0000757). Expressed support for H.R. 359 and S. 2095, the Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Discussed S. 3045, the Cybersecurity Vulnerability and Notification Act. Discussed S. 3418, the STORM Act. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed potential amendment to S. 2657, the American Energy Innovation Act, and the fiscal year 2021 National Defense Authorization Act to protect facilities with defense critical electric infrastructure. Discussed the need to bolster the Department of Energy's ability to protect critical electric infrastructure information. Discussed efforts by DOE to protect Defense Critical Electric Infrastructure. Provided feedback on S. 2556, the Protecting Resources on the Electric Grid with Cybersecurity Technology Act of 2019. Provided feedback on draft legislation, the Protecting Energy Infrastructure Act, to protect critical electric infrastructure information. Discussed the work the Office of Electricity at DOE is doing on defense critical electric infrastructure. Discussed S. 2094, the Enhancing State Energy Security Planning and Emergency Preparedness Act. Discussed support for language in S. 1706/H.R. 3079, the Energy Savings through Public-Private Partnerships Act, to carve out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Expressed opposition to efforts to remove such language from the legislation. Discussed efforts by the electric utility sector to ensure electric service during the COVID-19 pandemic, including efforts undertaken to protect utility workers, obtain testing for key utility personnel, and the need for personal protective equipment for key utility personnel. Discussed how public power utilities are addressing the COVID-19 pandemic, including the suspension of power shutoffs. Provided feedback on language in H.R. 6379, the Take Responsibility for Workers and Families Act, on power shutoffs and debt collection. Discussed the impact the COVID-19 pandemic is having on public power utilities and potential need for federal assistance in future COVID-19 legislation. Discussed public powers priorities in H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act, including increased funding for the Low Income Home Energy Assistance Program and aid to state and local governments. Provided feedback on H.R. 5760, the Grid Security R&D Act. Expressed support for S. 2657, the American Energy Innovation Act. Discussed FERC docket RM 18-9 and the need for state and local regulators to be able to consent to aggregation of distributed energy resources on distribution systems in their jurisdictions. Also discussed the particular burdens the proposed rule would have on small utilities. Discussed the impact of wholesale mandatory capacity market Minimum Offer Price rules and performance requirements on public power utilities. FERC docket EL 16-49/EL 18-178 and ER 18-1314. Discussed FERC docket No. PL 19-3 on transmission incentives. Discussed concerns with mandatory capacity markets in the Eastern RTOs and the need to ensure public powers ability to self-supply power in those markets. Expressed support for S. 1602, the Better Energy Storage Act of 2019; provided feedback and expressed support for H.R. 2986, the House version of the BEST Act. Provided feedback on H.R. 1744, the Storage Technology for Operational Readiness and Generating Energy Act. Provided feedback on an amendment to H.R. 5428, the Grid Modernization Research and Development Act of 2019. Discussed grid modernization issues.
Discussed APPA's opposition to President Trump's fiscal year 2021 budget proposal to divest the transmission assets of the Power Marketing Administrations (PMAs) and Tennessee Valley Authority and to require the PMAs to charge market-based rates. Lobbied for increased funding to the Environmental Protection Agency for federal and state permitting programs for coal combustion residuals in fiscal year 2021. Expressed support for making emergency supplemental funds appropriated to the Power Marketing Administrations, Army Corps of Engineers, and Bureau of Reclamation non-reimburseable in H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act. Supported additional funding for the Low Income Home Energy Assistance Program in H.R. 748, the Coronavirus Aid, Relief, and Economic Security Act.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Office of Management & Budget (OMB), SENATE, White House Office
Discussed potential ways to address third-party liability concerns during a grid security emergency. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Expressed support for H.R. 359 and S. 2095, the Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Discussed draft bulk-power system/supply chain executive order. Discussed potential amendment to the fiscal year 2020 National Defense Authorization Act, S. 1790, to protect facilities with defense critical electric infrastructure. Discussed the need to bolster the Department of Energy's ability to protect critical electric infrastructure information. Provided feedback on S. 2556, the Protecting Resources on the Electric Grid with Cybersecurity Technology Act of 2019. Provided feedback on draft legislation, the Protecting Energy Infrastructure Act,to protect critical electric infrastructure information. Discussed the work the Office of Electricity at DOE is doing on defense critical electric infrastructure. Provided feedback on H.R. 1975, the Cybersecurity Advisory Committee Authorization Act of 2019. Discussed FERC docket RM 18-9 and the need for state and local regulators to be able to consent to aggregation of distributed energy resources on distribution systems in their jurisdictions. Also discussed the particular burdens the proposed rule would have on small utilities. Discussed the impact of wholesale mandatory capacity market Minimum Offer Price rules and performance requirements on public power utilities. FERC docket EL 16-49/EL 18-178. Discussed Public Utility Regulatory Policies Act of 1978 reform being considered by the Federal Energy Regulatory Commission. FERC NOI -- Docket No. RM 19-15 and No. AD 16-16. Discussed FERC dockets ER 18-169 and ER 19-1428 on ISO-NE capacity markets and fuel security. Discussed FERC docket RM 16-23 and AD 16-20-001 on energy storage in wholesale markets. Discussed FERC docket No. PL 19-3 on transmission incentives. Discussed concerns with mandatory capacity markets in the Eastern RTOs and the need to ensure public powers ability to self-supply power in those markets. Expressed support for S. 1602, the Better Energy Storage Act of 2019, and provided feedback on H.R. 2986, the House version of the BEST Act. Provided feedback on H.R. 5428, the Grid Modernization Research and Development Act of 2019. Provided feedback on H.R. 5527, the 21st Century Power Grid Act. Provided feedback on draft legislation, the Interregional Transmission Planning Improvement Act of 2019, which is now S. 3109/H.R. 5511.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, Interior, Dept of (DOI), Office of Management & Budget (OMB), SENATE
Discussed potential ways to address third-party liability concerns during a grid security emergency. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Expressed support for H.R. 359 and S. 2095, the Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Provided feedback on S. 2094, the Enhancing State Energy Security Planning and Preparedness Act. Provided feedback on S. 2333, the Energy Cybersecurity Act of 2019. Discussed the status of the Cyberspace Solarium Commission. Discussed electromagnetic pulse provisions in the fiscal year 2020 National Defense Authorization Act, S. 1790. Discussed potential amendment on defense critical electric infrastructure to S. 1790, the fiscal year 2020 National Defense Authorization Act. Provided feedback on S. 2556, the the Protecting Resources on the Electric Grid with Cybersecurity Technology Act of 2019. Provided feedback on draft legislation, the Protecting Energy Infrastructure Act,to protect critical electric infrastructure information. Discussed the work the Office of Electricity at DOE is doing defense critical electric infrastructure. Discussed the proposed Federal Energy Regulatory Commission and National Electric Reliability Corporation (NERC) staff white paper on NERC Critical Infrastructure Protection violation notices. Discussed FERC docket RM 18-9 and the need for state and local regulators to be able to consent to aggregation of DERs on distribution systems in their jurisdictions. Also discussed the particular burdens the proposed rule would have on small utilities. Discussed the impact of wholesale mandatory capacity market Minimum Offer Price rules and performance requirements on public power utilities. Discussed Public Utility Regulatory Policies Act of 1978 reform being considered by Federal Energy Regulatory Commission. Discussed support for the inclusion of language to improve the hydropower licensing and relicensing reform process in an energy title to an infrastructure bill or as stand-alone legislation. Provided feedback on draft energy storage legislation, which become S. 1602, the Better Energy Storage Act of 2019. Provided feedback H.R. 4447, the Expanding Access to Sustainable Energy Act of 2019. Discussed concerns with mandatory capacity markets in the Eastern RTOs and the need to ensure public powers ability to self-supply power in those markets. Provided feedback on draft legislation to promote grid modernization research and development.
Discussed efforts by public power utilities to promote energy efficiency. Discussed support for H.R. 3962, the Energy Savings and Industrial Competitiveness Act of 2019. Discussed electric vehicles and the development of charging infrastructure by public power utilities. Expressed support for S. 674, the Clean Corridors Act of 2019, and the inclusion of the legislation in S. 2302, Americas Transportation Infrastructure Act of 2019. Lobbied on the need for a permanent repository for spent nuclear waste and in support of H.R. 2699, the Nuclear Waste Policy Amendments Act of 2019.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE
Discussed the exemption in Section 224 of the Communications Act that precludes Federal Communications Commission (FCC) regulation of public power pole attachments. Expressed opposition to any attempt to repeal or weaken the exemption. Expressed support for H.R. 530, the Accelerating Broadband Development by Empowering Local Communities Act of 2019, to repeal the FCC's report and order that seeks to regulate public power pole attachments. Expressed support for S. 2012, the Restoring Local Control Over Public Infrastructure Act. Expressed opposition to S. 1699, the STREAMLINE Small Cell Deployment Act. Discussed H.R. 1421, the HANGUP Act, that would subject the federal government to liability under the Telephone Consumer Protection Act (TCPA) and how it could impact public power utilities. Discussed the FCCs open docket on automated telephone dialer systems (FCC CG Docket Nos. 18-152 and 02-278) and how it could impact public power utilities. Discussed public powers concerns with FCC proceeding to open the 6 GHz band to unlicensed users (FCC ET Docket No. 18-295 and GN Docket No. 17-183).
Discussed H.R. 2548, the Hazard Eligibility and Local Projects Act, and expressed support for the legislation.
Discussed how public power and Department of Homeland Security can collaborate on grid security matters. Discussed potential cyber vulnerabilities that could arise from the supply chain and the need to ensure equipment used on the electric grid is secure. Discussed potential ways to address third-party liability concerns during a grid security emergency. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Provided feedback on and support for H.R. 359, the Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Provided feedback and support for H.R. 2114, the State Energy Security Planning and Emergency Preparedness Act. Discussed FERC docket RM 18-09 and the need for state and local regulators to be able to consent to aggregation of DERs on distribution systems in their jurisdictions. Also discussed the particular burdens the proposed rule would have on small utilities. Discussed concerns about rising transmission costs and potential impact of FERC notices of inquiry on incentives and equity returns (Dkt. PL19-3 and PL 19-4). Discussed transmission planning policies under Orders No. 890 and No. 1000. Discussed RTO governance issues. Discussed support for the inclusion of language to improve the hydropower licensing and relicensing reform process in an energy title to an infrastructure bill or as stand-alone legislation. Discussed support for language in draft legislation to carve out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. S. 1706/H.R. 3079 Discussed support for the inclusion of language in an energy title of an infrastructure bill to fund pilot projects on advanced distribution system management technologies. Discussed support for the inclusion of language to improve the siting of interstate natural gas pipelines in an energy title of an infrastructure bill. Discussed concerns with mandatory capacity markets in the Eastern RTOs and the need to ensure public powers ability to self-supply power in those markets. Discussed concerns with any proposed attempts by Congress to federalize rate design and how public power is working with its customers to enable distributed energy resources. Discussed S. 1760, the UPDATE PURPA Act. Discussed possible PURPA reform at Federal Energy Regulatory Commission. Discussed utility industry research on the potential impact to grid of an electromagnetic pulse. Provided feedback on energy storage legislation - S. 1602/H.R. 2986 and S. 1593/H.R. 1743 Discussed S. 1974, Renewable Electricity Standard Act.
Filing targets: Bureau of Land Management (BLM), Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), SENATE, U.S. Forest Service
Discussed potential cyber vulnerabilities that could arise from the supply chain and the need to ensure equipment used on the electric grid is secure. Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power, and how APPA is using funding to work with its members to improve their cyber hygiene. Provided feedback on and support for H.R. 359, the Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Discussed the electric utility industry's efforts to protect the grid and its close work with the federal government on cyber and physical security through the Electricity Subsector Coordinating Council. Provided feedback and support for H.R. 2114, the State Energy Security Planning and Emergency Preparedness Act. Provided feedback on draft legislation, the Grid Cybersecurity Research and Development Act, which would direct cyber research at the National Institute of Standards and Technology. Provided feedback on S. 881, the Space Weather Research and Forecasting Act, which would among other things safeguard infrastructure from space weather events. Discussed public powers concerns about rising transmission costs and the need for a proper determination about whether a project upgrade is actually needed. Discussed FERC docket RM 18-09 and the need for state and local regulators to be able to consent to aggregation of DERs on distribution systems in their jurisdictions. Also discussed the particular burdens the proposed rule would have on small utilities. Discussed developments in Western markets, including the impact of PG&Es bankruptcy on Western Market participants. Discussed support for the inclusion of language to improve the hydropower licensing and relicensing reform process in an energy title to an infrastructure bill or as stand-alone legislation. Discussed support for language in draft legislation to carve out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Discussed support for the inclusion of language in an energy title of an infrastructure bill to fund pilot projects on advanced distribution system management technologies. Discussed support for the inclusion of language to improve the siting of interstate natural gas pipelines in an energy title of an infrastructure bill. Discussed concerns with mandatory capacity markets in the Eastern RTOs and the need to ensure public powers ability to self-supply power in those markets. Discussed concerns with any proposed attempts by Congress to federalize rate design and how public power is working with its customers to enable distributed energy resources. Discussed support for H.R. 1502, the PURPA Modernization Act.
Discussed APPAs cooperative agreement with the Department of Energy (DE-OE-0000811), Improving the Cyber Resiliency and Security Posture of Public Power and how APPA is using funding to work with its members to improve their cyber hygiene. Requested continued funding for Cybersecurity for Energy Delivery Systems program in DOE's fiscal year 2020 budget. Discussed APPAs opposition to President Trumps fiscal year 2020 budget proposal to divest the transmission assets of the Power Marketing Administrations (PMAs) and Tennessee Valley Authority and to require the PMAs to charge market-based rates. Discussed public power support for adequate funding for the Low-Income Home Energy Assistance Program in fiscal year 2020. Lobbied for increased funding to the Environmental Protection Agency for federal and state permitting programs for coal combustion residuals in fiscal year 2020.
Filing targets: Bureau of Land Management (BLM), Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Interior, Dept of (DOI), SENATE
Supported the inclusion of the Disaster Recovery Reform Act in H.R. 302, the FAA Reauthorization Act of 2018. Specifically supported language to create a statute of limitations on the de-obligation of public assistance grants.
Discussed potential ways to change private-use restrictions on municipal bonds. Discussed the need to extend energy tax incentives to tax-exempt entities. H.R. 7196, the Energy Sector Innovation Act. Discussed carbon tax issues.
Lobbied for funding for cybersecurity in H.R. 5895, the Energy and Water Development Appropriations bill for fiscal year 2019.
Filing targets: Bureau of Land Management (BLM), Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, U.S. Forest Service
Discussed the need for a statute of limitations on the de-obligation of public assistance grants in disaster relief legislation -- H.R. 4460, the Disaster Recovery Reform Act, and S. 1641, the Post-Disaster Fairness to States Act. Supported the inclusion of the Disaster Recovery Reform Act in H.R. 302, the FAA Reauthorization Act of 2018.
Discussed the tax-exempt financing of public power infrastructure investments. Lobbied in support of H.R. 5003 to restore advance refunding bonds. Discussed potential ways to change private-use restrictions on municipal bonds. Discussed the need to extend energy tax incentives to tax-exempt entities. Discussed the issue of taxation of contributions in aid of construction.
Filing targets: Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Lobbied in support of funding for the Cybersecurity for Energy Delivery Systems program at the Department of Energy -- H.R. 1625, the Consolidated Appropriations Act, 2018. Expressed opposition to the President's FY 2019 proposal to divest the transmission assets of the Power Marketing Administrations (PMAs) and Tennessee Valley Authority and to change PMA rates from cost based to market based. Lobbied in support of an amendment to H.R. 5895, the Energy & Water Development Appropriations bill for fiscal year 2019, to prohibit the use of funds to carry out privatization of the PMAs and/or TVA. Expressed opposition to an amendment to H.R. 5895 that would reduce Western Area Power Administration Administrator Mark Gabriel's salary to $1 (Holman rule). Expressed opposition to the Administration's proposal to privatize the PMAs and TVA in its report on reorganizing and reforming the government. Expressed support for funding for restoration of Yucca Mountain as a permanent repository for spent nuclear fuel in H.R. 5895, the Energy & Water Development Appropriations Act for Fiscal Year 2019.
Expressed support for provisions in S. 2155, the Economic Growth, Regulatory Relief, and Consumer Protection Act, that classifies municipal bonds as high-quality liquid asset for bank capitalization requirements.
Provided feedback on and support for H.R. 5240, Enhancing Grid Through Public-Private Partnerships Act, to permanently authorize program assisting small- and medium-sized electric utilities with grid security. Provided feedback on H.R. 5239, Cyber Sense Act of 2018, to establish a volunteer program that identifies and promotes cyber-secure product intended for use in the bulk power system. Discussed the need for enhanced background screening of utility employees and provided feedback on draft legislation. Discussed support for legislation to improve the hydropower licensing and relicensing reform -- H.R. 3043 and provisions in S. 1460. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Discussed FERC policies on distributed energy resources -- FERC RM 16-23. Discussed FERC policies on use of tariffs in wholesale markets to promote bulk power grid resilience. Discussed support for H.R. 2910, legislation to expedite the permitting of interstate natural gas piplelines. Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests, as well as ensuring public power's right to self-supply. Discussed concerns with any proposed attempts by Congress to federalize rate design and how public power is working with its customers to enable distributed energy resources. Discussed concerns with wholesale markets and FERC intrusion into energy matters that fall within state/local jurisdiction under the Federal Power Act. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Discussed FERC's order on grid resiliency -- FERC RM 18-1. Discussed implementation of vegetation management legislation, H.R. 1873, included in H.R. 1625, the Consolidated Appropriations Act, 2018, by the U.S. Forest Service and Bureau of Land Management. Lobbied in support of H.R. 587, the FAIR Rates Act. Discussed electric industry's close work with Canada on bulk power system issues.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE, Transportation, Dept of (DOT)
Lobbied in support of funding for the Cybersecurity for Energy Delivery Systems program at the Department of Energy -- H.R. 1625, the Consolidated Appropriations Act, 2018. Expressed opposition to the President's FY 2019 proposal to divest the transmission assets of the Power Marketing Administrations (PMAs) and Tennessee Valley Authority and to change PMA rates from cost based to market based. Expressed opposition to including language on electromagnetic pulse in H.R. 1625, the Consolidated Appropriations Act, 2018.
Discussed the tax-exempt financing of public power infrastructure investments. Lobbied in support of H.R. 5003 to restore advance refunding bonds. Discussed potential ways to change private use restrictions on municipal bonds.
Filing targets: Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Discussed efforts to restore power after Hurricanes Harvey, Irma, and Maria. Discussed the mutual aid process for public power utilities. Expressed support for presidential granting of 100 percent reimbursement for category A and B costs for Puerto Rico in the aftermath of Hurricane Maria -- FEMA cost sharing for Notice of Major Disaster for the Commonwealth of PR (FEMA 4339-DR)
Lobbied in support of funding for Cybersecurity for Energy Delivery Systems program at the Department of Energy -- H.R. 3266/S. 1609 -- Energy and Water Appropriations Act of 2018.
Lobbied on the tax treatment of municipal bonds; lobbied on provisions affecting tax treatment of disaster bonds -- H.R. 1, the Tax Cuts and Jobs Act.
Discussed burden of complying with regulation of swaps with utility special entities - H.R. 238, the Commodity End User Relief Act.
Filing targets: Commodity Futures Trading Commission (CFTC), Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Lobbied in support of wholesale electricity market reforms with focus on capacity markets and protecting customer interests. Lobbied on the need to protect public power and consumer interests in the potential expansion of the California ISO. Discussed the importance of the electric utility industry and government partnership to share information and work together on grid security; discussed regulations on grid security; discussed industry efforts on the potential threat of electromagnetic pulse to the electric grid -- S.1519, H.R. 2910-- supporting modification of provisions regarding EMPs Discussed need for legislation to improve the hydropower licensing and relicensing reform, including support for H.R. 3043 and provisions in S. 1460. Discussed need for legislation to improve interstate natural gas pipeline permitting process, including support for H.R. 2910 and provisions in S. 1460. Discussed need for legislation on vegetation management and in support of H.R. 1873. Also support vegetation management language in S. 1460, Energy & Natural Resources Act of 2017. Lobbied in support of congressional oversight of the implementation of the Federal Power Act. Discussed issues related to distributed generation, including rate design and microgrids. Provided feedback on draft bills to promote distributed energy resources. Also provided feedback on S. 1874, Distributed Energy Demonstration Act of 2017, S. 1875, the Flexible Grid Infrastructure Act of 2017, and S. 1876, Reducing the Cost of Energy Storage Act of 2017. Discussed the need for enhanced background screening of utility employees. Discussed language in H.R. 723/S. 239 that carves out federal hydropower facilities from the definition of eligible federal facilities that can use energy savings performance contracts. Provided feedback on proposed legislation permanently authorizing program assisting small- and medium-sized utilities with grid security. Discussed needed reforms to the Public Utility Regulatory Policies Act of 1978. Discussed issues being examined in DOE study on grid reliability, including wholesale markets, renewables, and hydropower. Discussed the following dockets at FERC: -- State Policies and organized wholesale markets (FERC Dkt. AD17-11) -- Electric storage participation in RTO/ISO markets (FERC Dkt. RM16-23) -- FERC price formation dockets (FERC Dkt. RM17-03; RM17-20)
Lobbied in support of preserving the tax-exempt status of municipal bonds in any tax reform proposal and its importance for financing public power infrastructure.
Filing targets: Energy, Dept of, Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Office of Management & Budget (OMB), SENATE, White House Office
Lobbied in support of funding for Cybersecurity for Energy Delivery Systems program at the Department of Energy. Discussed opposition to fiscal year 2018 budget proposal from President that recommends selling the transmission assets of the Power Marketing Administrations. Lobbied in support of Power Marketing Administrations and TVA. Also discussed issues specific to the Western Area Power Administration.
Lobbied in support of preserving the tax-exempt status of municipal bonds in any tax reform proposal and its importance for financing public power infrastructure. Lobbied in support of legislation on the nuclear production tax credit -- H.R. 1551 and S. 666. Discussed how public power cannot receive renewable energy tax credits as not-for-profit entities and the need for comparable incentives. Discussed S. 1068, the Clean Energy for America Act. Discussed the impact of sequestration on Build America Bonds issued by public power.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), HOUSE OF REPRESENTATIVES, SENATE, White House Office
Lobbied to add language to H.R. 5, the Regulatory Accountability Act of 2017, to change the existing definition of small governmental entity to address problem such definition creates for public power utilities. Also lobbied on same issue in H.R. 33, the Small Business Regulatory Flexibility Act, and S. 584.
Lobbied in support of preserving the tax-exempt status of municipal bonds in any tax reform proposal and its importance for financing public power infrastructure. Lobbied in support of legislation on the nuclear production tax credit -- H.R. 1551 and S. 666. Discussed how public power cannot receive renewable energy tax credits as not-for-profit entities and the need for comparable incentives.
Discussed support for provisions in H.R. 238, the Commodity End User Relief Act, regarding swap dealer de minimus threshold.
Lobbied in support of funding for Cybersecurity for Energy Delivery Systems program at the Department of Energy. Discussed potential for new fiscal year 2018 budget proposal from President to recommend privatizing Tennessee Valley Authority (TVA) and to sell Power Marketing Administrations. Lobbied in support of Power Marketing Administrations and TVA. Lobbied in support of funding for Low Income Home Energy Assistance Program in H.R. 5926 and S. 3040, the Departments of Labor, Health and Human Services, and Education, and Related Agencies Appropriations Act, 2017.
Filing targets: Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Lobbied on definition of small entity under regulatory flexibility act, H.R. 527/S. 1536, Small Business Regulatory Flexibility Improvements Act
Discussed issues of importance to public power in S. 2012, the Energy Policy Modernization Act of 2016 (House and Senate versions), including provisions on capacity markets, grid security, grid modernization, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, reliability, vegetation management, and geomagnetic disturbances/electromagnetic pulses. Discussed issues surrounding distributed generation and concerns with attempts to federalize what is a state/local jurisdictional issue. Expressed concerns about regional transmission organizations markets, including a proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally and how the Federal Power Act is being implemented. Lobbied in support of protecting consumers interests in regional transmission organizations and independent system operator markets. Discussed implications of the expansion of the California ISO in the West for public power utilities. Lobbied on H.R. 1073/S.1846, preserving the directing NERC-FERC model for grid security regulations. Lobbied on S. 3017 -- cybersecurity provision directing DNI and DHS to provide voluntary assistance from the intelligence community to certain critical infrastructure owners/operators. Supported oversight efforts on Federal Power Act.
Lobbied in support of H.R. 2984, Fair Rates Act of 2016 -- legislation regarding FERC-approved tariff changes.
Filing targets: Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Discussed the need to monitor implementation of H.R. 2029, the Cybersecurity Act of 2015, and H.R. 22, the Fixing Americas Surface Transportation Act. Provided feedback on the provisions in H.R. 6227, the Grid Cybersecurity Research and Development Act. Discussed issues of importance to public power in S. 2012, the Energy Policy Modernization Act of 2016 (House and Senate versions), including provisions on capacity markets, grid security, grid modernization, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, reliability, vegetation management, and geomagnetic disturbances/electromagnetic pulses. Lobbied in support of House and Senate going to conference. Discussed issues surrounding distributed generation and concerns with attempts to federalize what is a state/local jurisdictional issue. Expressed concerns about regional transmission organizations markets, including a proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally and how the Federal Power Act is being implemented. Lobbied in support of protecting consumers interests in regional transmission organizations and independent system operator markets. Discussed implications of the expansion of the California ISO in the West for public power utilities.
Lobbied on funding for low income heating assistance in H.R. 5926/S. 3040, the Fiscal Year 2017 Labor, Health and Human Services, and Education Appropriations Act.
Filing targets: Energy, Dept of, Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, SENATE
Discussed the need to monitor implementation of H.R. 2029, the Cybersecurity Act of 2015, and H.R. 22, the Fixing Americas Surface Transportation Act. Discussed issues of importance to public power in H.R. 8, the North American Energy Security and Infrastructure Act of 2015, including provisions on capacity markets, grid security, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, reliability, and geomagnetic disturbances/electromagnetic pulses. Discussed issues of importance to public power in S. 2012, the Energy Policy Modernization Act of 2015, including provisions on capacity markets, grid security, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, and reliability. Lobbied in support of S. 2012. Discussed issues surrounding distributed generation and concerns with attempts to federalize what is a state/local jurisdictional issue. Advocated on the need for small utilities that are defined as small businesses under the Small Business Regulatory Enforcement Fairness Act to get appropriate consideration under any pending and future EPA and FERC regulations. Worked to ensure that S. 1536, the Senate companion bill to H.R. 527, includes language to fix Small Business Administration size standard issue. Expressed concerns about regional transmission organizations markets, including a proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally. Advocated in favor of H.R 2984, the Fair RATES Act re: FERC regulations. Discussed DOEs Quadrennial Energy Review 1.2. Lobbied on S. 1846, the Critical Infrastructure Act of 2016/H.R. 1073, to amend the Homeland Security Act of 2002 to secure critical infrastructure against electromagnetic threats, and for other purposes. Sought to preserve the current NERC-FERC model for grid security regulations. Lobbied in support of protecting consumers interests in regional transmission organizations and independent system operator markets. Discussed implications of the expansion of the California ISO in the West for public power utilities.
Supported H.R 2289, the Commodity End-User Relief Act that addresses the treatment of swaps with utility special entities. Lobbied in opposition to CFTC effort to allow private right of action on FERC-jurisdictional transactions.
Lobbied on provisions in H.R. 527/S.1536, the Regulatory Flexibility Improvements Act regarding definition of small governmental entities.
Filing targets: Energy, Dept of, Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), SENATE, Surface Transportation Board (STB)
Discussed the need to monitor implementation for H.R. 2029, the Cybersecurity Act of 2015, and H.R. 22, the Fixing Americas Surface Transportation Act. Discussed issues of importance to public power in H.R. 8, the North American Energy Security and Infrastructure Act of 2015, including provisions on capacity markets, cybersecurity, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, reliability. Discussed issues of importance to public power in S. 2012, the Energy Policy Modernization Act of 2015, including provisions on capacity markets, cybersecurity, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, reliability, geomagnetic disturbances/electromagnetic pulses, and emergency coal fuel supplies. Lobbied in support of S. 2012. Opposed amendments to federalize distributed generation. Supported amendments to modify or eliminate Section 1222 of EPAct05. Expressed support for the inclusion of language to ensure the ability of public power to self-supply in S. 2012. Advocated on the need for small utilities that are defined as small businesses under the Small Business Regulatory Enforcement Fairness Act to get appropriate consideration under any pending and future EPA and FERC regulations. Worked to ensure that S. 1536, the Senate companion bill to H.R. 527, includes language to fix Small Business Administration size standard issue. Expressed concerns about regional transmission organizations markets, including a proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally. Discussed issues surrounding distributed generation and concerns with attempts to federalize what is a state/local jurisdictional issue. Expressed support for S. 485, the APPROVAL ACT, Assuring Private Property Rights Over Vast Access to Land Act. Advocated in favor of H.R 2984, the Fair RATES Act re: FERC regulations. Discussed DOEs Quadrennial Energy Review 1.2. Reviewed and provided feedback to Senate Commerce Committee staff on a discussion draft re: space weather.
Advocated for passage of H.R. 2041/S.1111, the Public Power Risk Management Act - modifying final rule on swap dealers under the Dodd-Frank Wall Street Reform Act regarding special entities and the $25 million ceiling on their hedging transactions. Supported more limited role in Dodd-Frank for non-profit energy end-users. Supported funding for CFTC so that it can properly manage implementation of Dodd-Frank. Supported H.R 2289, the Commodity End-User Relief Act that addresses the treatment of swaps with utility special entities.
Expressed opposition to modifying or eliminating tax-exempt financing in any budget proposal, including FY 2017 Administration proposal to cap deductions at 28 percent for higher income earners. Expressed support for Low-Income Home Energy Assistance Program (LIHEAP) funding. Advocated on H.R. 2898 and S. 1894 re: allocation of costs at Bureau of Reclamation Hydropower Facilities.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), SENATE, Treasury, Dept of, White House Office
Monitored issues related to unmanned aerial vehicles (UAV), and advocated the use of UAV for utility related operations (Docket FAA-2015-0150). Monitoring Federal Aviation Administration re-authorization legislation for related developments.
Advocated for passage of information sharing legislation such as the S. 754, Cybersecurity Information Sharing Act of 2015, H.R. 1560, the Protecting Cyber Networks Act, and H.R. 1731, the National Cybersecurity Protection Advancement Act of 2015. Advocated for public power language in conference committee and supported cybersecurity bill in omnibus appropriations bill. Discussed the need for enhanced liability protection for electric utilities that are subject to a cybersecurity attack. Supported H.R. 22, the Fixing Americas Surface Transportation Act. Advocated for grid security provisions from H.R. 8 to be included in this bill once the amendment was filed; negotiated with House and Senate to retain in H.R. 22. Opposed H.R. 1073, the Critical Infrastructure Protection Act, S. 1241, the Enhanced Grid Security Act of 2015, and S.1846, a bill to amend the Homeland Security Act of 2002 to secure critical infrastructure against electromagnetic threats, and for other purposes. S. 720, the Energy Savings and Industrial Competitiveness Act of 2015 and H.R. 873, a bill to promote energy efficiency, and for other purposes. Discussed potential comprehensive energy legislation with House and Senate staff. Supported efforts to delete Section 433 of EISA 2007 of S. 869, which mandates that all federal buildings use no fossil fuel by 2030. Advocated for specific positions to be included in H.R. 8, the North American Energy Security and Infrastructure Act of 2015, which has provisions on capacity markets, cybersecurity, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, and reliability. Opposed certain distributed generation/PURPA amendments to H.R. 8 during floor consideration. Also, advocated on similar issues in S. 2012, the Energy Policy Modernization Act of 2015. Continued working to ensure that small utilities that are defined as small businesses under the Small Business Regulatory Enforcement Fairness Act get appropriate consideration under any pending and future EPA and FERC regulations. Worked to ensure that S. 1536, the Senate companion bill to H.R. 527, which modified the Regulatory Flexibility Act, included language to fix Small Business Administration size standard issue. Expressed support for H.R. 2358, the Electricity Reliability and Forest Protection Act, that was approved by the House Committee on Natural Resources. Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally. While not a federal issue, discussed issues surrounding distributed generation (namely, rooftop solar) with DOE staff and with some offices on Capitol Hill such that it remains at state/local issue. Discussed the issue of the availability of spare transformers with DOE and others. Expressed support for S. 485, the APPROVAL ACT, Assuring Private Property Rights Over Vast Access to Land Act.
Opposed any efforts to change the purpose of the Power Marketing Administrations (PMAs) from marketing clean federal hydropower. Relayed APPA concerns to Department of Energy regarding dam safety cost allocation and asked to look into signing letter on F.R Docket 2015-12888. Opposed to modifying or eliminating tax-exempt financing in any budget proposal, including FY 2016 Administration proposal to cap deductions at 28 percent for higher income earners. Monitored Nuclear Regulatory Commission appropriations allocations for the Department of Energy, the federal Power Marketing Administrations, and the Commodity Futures Trading Commission. Supported Low-Income Home Energy Assistance Program (LIHEAP) funding.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), SENATE, Treasury, Dept of, White House Office
Opposed any efforts to change the purpose of the Power Marketing Administrations (PMAs) from marketing clean federal hydropower to promoting non-hydro renewables -- monitored Department of Energy activities on the PMAs. Relayed APPA concerns to Department of Energy regarding dam safety cost allocation and asked to look into signing letter on F.R Docket 2015-12888. Opposed to modifying or eliminating tax-exempt financing in any budget proposal, including FY 2016 Administration proposal to cap deductions at 28 percent for higher income earners. Monitored Nuclear Regulatory Commission appropriations allocations for the Department of Energy, the federal Power Marketing Administrations, and the Commodity Futures Trading Commission.
Monitored information sharing legislation such as the S. 754, Cybersecurity Information Sharing Act of 2015, H.R. 1560, the Protecting Cyber Networks Act, and H.R. 1731, the National Cybersecurity Protection Advancement Act of 2015. Discussed the need for enhanced liability protection for electric utilities that are subject to a cybersecurity attack. Opposed to H.R. 1073, the Critical Infrastructure Protection Act, S. 1241, the Enhanced Grid Security Act of 2015, and S.1846, a bill to amend the Homeland Security Act of 2002 to secure critical infrastructure against electromagnetic threats, and for other purposes. Continued support of revised energy efficiency legislation - S. 535, the Energy Efficiency Improvement Act of 2015, S. 720, the Energy Savings and Industrial Competitiveness Act of 2015, H.R. 906, a bill to modify the efficiency standards for grid-enabled water heaters, and H.R. 873, a bill to promote energy efficiency, and for other purposes. Discussed potential comprehensive energy legislation with House and Senate staff. Supported efforts to delete Section 433 of EISA 2007 of S. 869. which mandates that all federal buildings use no fossil fuel by 2030. Advocated for specific positions to be included in H.R. 8, the North American Energy Security and Infrastructure Act of 2015, that included provisions on capacity markets, cybersecurity, distributed generation, energy efficiency, hydropower licensing reform, pipeline permitting, reliability, self-supply, wholesale energy markets, and workforce development. Also, advocated for positions to be included in the drafting process of S. 2012, the Energy Policy Modernization Act of 2015. APPA supports underlying emergency authority sections in both bills, but think cost-recovery is duplicative and unnecessary. APPA believes states need preemption from sunshine law application to targeted critical infrastructure information. APPA supports FERC review of reliability implications of major rules. APPA supports streamlining of hydropower licensing reform processes. APPA opposes codification of PJM performance capacity rules. APPA supports provisions to ensure public powers ability to self-supply its own customers. APPA supports pipeline permitting reform and workforce development provisions. Continued working to ensure that small utilities that are defined as small businesses under the Small Business Regulatory Enforcement Fairness Act get appropriate consideration under any pending and future EPA and FERC regulations. Worked to ensure that S. 1536, the Senate companion bill to H.R. 527, which modified the Regulatory Flexibility Act, included language to fix Small Business Administration size standard issue. Expressed support for H.R. 2358, the Electricity Reliability and Forest Protection Act that was approved by the House Committee on Natural Resources. Expressed concerns about or opposition to markets issues related to regional transmission organizations, including proposed energy imbalance market and existing mandatory capacity markets. Encouraged oversight of FERC more generally. While not a federal issue, discussed issues surrounding distributed generation (namely, rooftop solar) with DOE staff and with some offices on Capitol Hill. Discussed the issue of the availability of spare transformers with DOE and others. Expressed support for S. 485, the APPROVAL ACT, Assuring Private Property Rights Over Vast Access to Land Act. Advocated for SEPA rate proposal regarding cost allocation at the Center Hill and Wolf Creek dams. Provisions related to cost allocation of federally-owned dams. Monitored Southeastern Federal Power Administration Rate making procedures.
Monitor issues related to unmanned aerial vehicles (UAV), including use of UAV for utility related operations (Docket FAA-2015-0150). Monitoring Federal Aviation Administration re-authorization legislation for related developments.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), SENATE, Treasury, Dept of, White House Office
Worked to re-introduce H.R. 2041/S.1111, the Public Power Risk Management Act - modifying final rule on swap dealers under the Dodd-Frank Wall Street Reform Act regarding special entities and the $25 million ceiling on their hedging transactions. Supported more limited role in Dodd-Frank for non-profit energy end-users. Supported funding for CFTC. Supported H.R 2289, the Commodity End-User Relief Act that addresses the treatment of swaps with utility special entities.
Monitor issues related to unmanned aerial vehicles (UAV), including use of UAV for utility related operations (Docket FAA-2015-0150). Monitoring FAA re-authorization legislation for related developments.
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Monitored impacts of sequestration on Build America Bonds (BABs). Expressed support for S. 485, the APPROVAL ACT, Assuring Private Property Rights Over Vast Access to Land Act.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), SENATE, Treasury, Dept of, White House Office
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions and legislation to tax municipal bonds. Monitored impacts of sequestration on Build America Bonds (BABs).
Worked to re-introduce the Public Power Risk Management Act - modifying final rule on swap dealers under the Dodd-Frank Wall Street Reform Act regarding special entities and the $25 million ceiling on their hedging transactions. Supported more limited role in Dodd-Frank for non-profit energy end-users. Supported funding for CFTC.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Federal Aviation Administration (FAA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), SENATE, Treasury, Dept of, White House Office
Opposed any efforts to change the purpose of the PMAs from marketing clean federal hydropower to promoting non-hydro renewables -- still monitoring DOE activities on the PMAs. Opposed to modifying or eliminating tax-exempt financing in any budget proposal, including FY 2015 Administration proposal to cap deductions at 28 percent for higher income earners. Oppose proposal in President's FY 2015 budget to continue to investigate divestiture of TVA. Monitored H.R. 83, the Omnibus Appropriations bill,related to appropriations allocations for the Department of Energy, the federal Power Marketing Administrations, and the Commodity Futures Trading Commission, as well as policy riders related to environmental issues such as the Waters of the U.S. proposal by EPA, and the regulation of greenhouse gas emissions from existing power plants proposal by EPA. Supported such policy riders.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Supported legislation, S. 1802, modifying final rule on swap dealers under the Dodd-Frank Wall Street Reform Act regarding special entities and the $25 million ceiling on their hedging transactions (S. 1802 is a companion bill to H.R. 1038, which previously has passed the House) Supported more limited role in Dodd-Frank for non-profit energy end-users. Supported funding for CFTC. Support including H.R. 1038/S. 1802 in CFTC Reauthorization bill.Supported the CFTC in rulemaking (RIN 3038-AE19) allow special entities to hedge by engaging in swap transactions in the same way as do other types of electric utiltiies, and generally supported final rule.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2015 budget proposal, to tax municipal bonds. Support H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs), including H.R. 789 and H.J.Res. 59.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Supported legislation, H.R. 1038, modifying final rule on swap dealers under the Dodd-Frank Wall Street Reform Act regarding special entities and the $25 million ceiling on their hedging transactions -- H.R. 1038 passed the House, and is pending in the Senate -- Senate version introduced in December as S. 1802. Supported more limited role in Dodd-Frank for non-profit energy end-users. Supported funding for CFTC. Support including H.R. 1038/S. 1802 in CFTC Reauthorization bill. Support CFTC no-action letterallowing special entities to hedge by engaging in swap transactions in the same way as do other types of electric utilities. Support the CFTC for stating its desire to undertake a rulemaking to address this issue as well.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Opposed to DOE Secretary Chu memo of March 16, 2012, to drastically change the purpose of the PMAs from marketing federal hydropower to promoting non-hydro renewables -- still monitoring DOE activities on the PMAs. Opposed to modifying or eliminating tax-exempt financing in any budget proposal, including FY 2014 Administration proposal to cap deductions at 28 percent for higher income earners. Oppose proposal in President's FY 2014 budget to investigate divestiture of TVA.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Supported the continued use of tax-exempt financing for municipal/public power purposes, and opposed provisions, like those included in the Administration's FY 2014 budget proposal, to tax municipal bonds. Support H. Res. 112, highlighting the value of tax-exempt financing, and authored by Reps. Terry and Neal. Monitored impacts of sequestration on Build America Bonds (BABs). Opposed S.Con.Res. 8 because of proposal that could lead to limiting tax-exempt financing.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Opposed DOE Secretary Chu memo of March 16, 2012, to drastically change the purpose of the PMAs from marketing federal hydropower to promoting non-hydro renewables. Opposed to modifying or eliminating tax-exempt financing in any budget proposal, including FY 2014 Administration proposal to cap deductions at 28 percent for higher income earners. Oppose proposal in President's FY 2014 budget to investigate divestiture of the Tennessee Valley Authority (TVA).
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Opposed DOE Secretary Chu memo of March 16, 2012, to drastically change the purpose of the PMAs from marketing federal hydropower to promoting non-hydro renewables. Opposed to modifying or eliminating tax-exempt financing in any budget proposal, including FY 2014 Administration proposal to cap deductions at 28 percent for higher income earners.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Opposed taking the Power Marketing Administrations (PMAs) to market-based as opposed to cost-based rates in any budget proposal. Opposed DOE Secretary Chu memo of March 16, 2012, to drastically change the purpose of the PMAs from marketing federal hydropower to promoting non-hydro renewables. Opposition to eliminating tax-exempt financing in any budget proposal.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Support for Power Marketing Administration funding and operation and maintenance of hydropower facilities at hydropower facilities at Corps of Engineers and Bureau of Reclamation dams. Opposition to taking the Power Marketing Administrations (PMAs) to market-based as opposed to cost-based rates in any budget proposal. Opposition to DOE Secretary Chu memo of March 16, 2012, to drastically change the purpose of the PMAs from marketing federal hydropower to promoting non-hydro renewables. Opposition to eliminating tax-exempt financing in any budget proposal. Support for the Low-Income Home Energy Assistance Program.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Executive Office of the President (EOP), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Homeland Security, Dept of (DHS), Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), Nuclear Regulatory Commission (NRC), Office of Management & Budget (OMB), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office
Monitoring implementation of legislation, H.R. 4173 (known as the Frank-Dodd Wall Street Reform Act), regulating over-the-counter derivatives markets that our members use to hedge natural gas and electricity prices, to ensure that exemptions for end-users of energy from mandatory clearing are retained, and opposing final rule on swap dealers regarding special entities and the $25 million ceiling on their transactions. Also support more limited role in Dodd-Frank for non-profit end-users.
Filing targets: Commodity Futures Trading Commission (CFTC), Energy, Dept of, Environmental Protection Agency (EPA), Federal Communications Commission (FCC), Federal Emergency Management Agency (FEMA), Federal Energy Regulatory Commission (FERC), HOUSE OF REPRESENTATIVES, Internal Revenue Service (IRS), Natl Telecommunications & Information Administration (NTIA), SENATE, Surface Transportation Board (STB), Treasury, Dept of, White House Office